Janelle Quinn v. Columbia County School District

August, Georgia, civil rights lawyer represented the Plaintiff on a education civil rights violation theory.<br>
<br>
Quinn filed this suit in April 2022. In her complaint, she set<br>
out two claims: racial discrimination under Title VI ("Count One”),<br>
and retaliation under Title VI ("Count Two”). Importantly, Count<br>
One was brought on behalf of D.J.Q. and Count Two was brought<br>
on behalf of both Quinn and D.J.Q. After discovery, the District<br>
moved for summary judgment. Quinn opposed the District's mo-<br>
tion, and the parties submitted various evidence in support of their<br>
positions. The evidence the parties submitted, construed in the<br>
light most favorable to Quinn, see Guevara v. Lafise Corp., 127 F.4th<br>
824, 828 (11th Cir. 2025), showed the following.<br>
<br>
Quinn's child, D.J.Q., was enrolled at Parkway Elementary<br>
School ("Parkway”) for the 2020-21 school year. Columbia County<br>
manages and controls Parkway. Quinn was a Military and Family<br>
Life Counselor whom Magellan Federal ("Magellan”), a third<br>
party, assigned to work at two schools within Columbia County<br>
during the 2020-21 school year: Parkway and Greenbrier Elemen-<br>
tary School. Quinn and D.J.Q. are both Black. In January 2021,<br>
during lunch, D.J.Q. sought the attention of Julie Owens, a White<br>
counselor who worked at Parkway, to request a different eating<br>
utensil. Instead of providing D.J.Q with a new utensil, Owens took<br>
the eating utensil D.J.Q. was holding, placed it in D.J.Q.'s mouth,<br>
removed it, and placed it back in D.J.Q.'s hand, telling him to<br>
"clean” the utensil he had. Owens then went back to her lunch<br>
duties and D.J.Q. continued to eat his lunch with the utensil he al-<br>
ready had. Later that day, D.J.Q. told his mother that he had "the<br>
worst day ever” and described the incident. He also reported being<br>
uncomfortable and anxious to be around Owens going forward.<br>
The next day, Quinn and her husband met with the principal<br>
of Parkway, Dr. Michael Doolittle, about the incident. During the<br>
meeting, neither Quinn nor her husband expressed any concern<br>
that Owens's behavior was discriminatory or racially motivated.<br>
Owens, however, apologized to D.J.Q. and Quinn and, in Dr. Doo-<br>
little's view, D.J.Q. accepted her apology. Still, Dr. Doolittle re-<br>
ported the incident to his supervisor, Dr. Deborah Williams. Dr.<br>
Doolittle, Dr. Williams, and the Superintendent of Columbia<br>
County Schools, Sandra Carraway, also reviewed video footage of<br>
the incident, and the District instituted efforts to prevent contact<br>
between Owens and D.J.Q.<br>
<br>
Quinn sent a letter to the Board of Education on January 24,<br>
2021, in which she explained that the incident "was humiliating”<br>
and put D.J.Q. at risk due to the pandemic. She also stated that<br>
"[a]n apology” was "a far cry from enough.” She "call[ed] on the<br>
Columbia County Board of Education to . . . stand up for our chil-<br>
dren and strongly condemn this sort of behavior,” but she did not<br>
specify what action she wanted the Board to take.<br>
Quinn, Dr. Doolittle, and Dr. Williams had another meeting<br>
in late February. At this meeting, Quinn reported, for the first<br>
time, that she believed that the incident was a racist act. Quinn had<br>
no knowledge of Owens ever taking action toward another person<br>
based on race or skin color and had heard no complaints from<br>
D.J.Q. about Owens before the January 2021 incident. However,<br>
Quinn alleged that Owens had made comments in the past suggest-<br>
ing racial animus, such as stating that there were "too many Mexi-<br>
cans in Walmart.” Dr. Doolittle reported that he had never before<br>
received a complaint of discrimination against Owens, and Quinn<br>
admitted that she had not witnessed any behavior between Owens<br>
and other students of any race.<br>
<br>
Unsatisfied with the District's response, Quinn made several<br>
additional reports about the incident, including to the Professional<br>
Standards Commission and the U.S. Department of Justice. In<br>
April 2021, Quinn filed a police report with the Columbia County<br>
Sheriff's Office because she believed that Owens should be charged<br>
24-11570 Opinion of the Court 5<br>
<br>
with either assault or battery. The report to the Sheriff's Office<br>
made Owens "distraught” and she was sent home from the school.<br>
In April, Dr. Doolittle reported the ongoing situation to Dr. Wil-<br>
liams's replacement, Associate Superintendent Michele Sherman.<br>
Quinn did not, however, report the incident to her employer, Ma-<br>
gellan.

The district court ultimately granted the District’s motion<br>
for summary judgment as to both of Quinn’s Title VI claims<br>
<br>
Affirmed