In a case of first impression, Quigg v. Thomas County School District, the U.S. Eleventh Circuit Court of Appeals rejected the burden-shifting framework (known as “McDonell Douglas”) established by the U.S. Supreme Court in 1973 for cases involving mixed-motive discrimination claims. Instead, the Court adopted a less stringent standard, allowing claims to proceed where the plaintiff is able to show that (1) the defendant took an adverse employment action against the plaintiff and (2) a protected characteristic was a motivating factor for the adverse employment action.