The U.S. Court of Appeals for the Eleventh Circuit has affirmed a district court's grant of summary judgment in favor of the City of Sylvester, Georgia, and Police Chief Raymond Drennon in a civil rights lawsuit filed by former police officer Demetric King. The unpublished opinion, issued Jan. 21, 2026, resolves King's appeal from the U.S. District Court for the Middle District of Georgia.
King, who served as a police officer with the City of Sylvester, filed suit against his former employer and supervisor alleging race discrimination and retaliation. His lawsuit included claims under 42 U.S.C. §§ 1981 and 1983, Title VII of the Civil Rights Act of 1964, and the Family and Medical Leave Act.
The case centers on King's termination from the police department and his allegations that the adverse employment actions he faced were motivated by racial bias and retaliation for protected activities. King claimed that both his demotion and ultimate termination were discriminatory and violated federal civil rights laws.
The district court granted summary judgment in favor of the defendants after determining that King had failed to present sufficient evidence to support his claims. Specifically, the trial court found that King could not demonstrate that the defendants' stated reasons for terminating him were merely pretextual - a key element in employment discrimination cases.
Under employment discrimination law, once an employer provides a legitimate, non-discriminatory reason for an adverse employment action, the burden shifts to the plaintiff to show that the stated reason is pretext for discrimination. The district court concluded that King had not met this burden.
The court also applied two different analytical frameworks commonly used in discrimination cases: the McDonnell Douglas test and the "convincing mosaic" standard. Under both approaches, the district court determined that King had failed to show that race was a motivating factor in either his demotion or termination.
The McDonnell Douglas test, established by the Supreme Court in *McDonnell Douglas Corp. v. Green* (1973), provides a burden-shifting framework for analyzing discrimination claims. Under this test, a plaintiff must first establish a prima facie case of discrimination, after which the burden shifts to the defendant to articulate a legitimate reason for the employment action. The burden then returns to the plaintiff to show that the stated reason is pretextual.
The "convincing mosaic" standard, used in some circuits, allows plaintiffs to establish discrimination through circumstantial evidence that, when viewed as a whole, creates a convincing picture of discriminatory intent. The district court found that King's evidence failed to meet either standard.
Regarding King's retaliation claims under the FMLA and Title VII, the district court ruled that King had not provided sufficient evidence to support these allegations. Both statutes prohibit employers from retaliating against employees who exercise their rights under the respective laws or oppose discriminatory practices.
The FMLA provides eligible employees with unpaid, job-protected leave for specified family and medical reasons. Title VII prohibits employment discrimination based on race, color, religion, sex, or national origin, and also contains anti-retaliation provisions protecting employees who oppose discriminatory practices or participate in discrimination proceedings.
The Eleventh Circuit panel, consisting of Circuit Judges Rosenbaum, Abudu, and Wilson, with Judge Abudu writing the opinion, reviewed the district court's decision and determined that the lower court properly granted summary judgment. Circuit Judge Abudu authored the opinion for the three-judge panel.
Summary judgment is appropriate when there is no genuine dispute as to any material fact and the moving party is entitled to judgment as a matter of law. In employment discrimination cases, courts often grant summary judgment when plaintiffs cannot present evidence sufficient to allow a reasonable jury to find in their favor.
The decision is designated "NOT FOR PUBLICATION," meaning it will not be published in the Federal Reporter and has limited precedential value. Unpublished opinions are typically used for cases that apply established legal principles to particular facts without breaking new legal ground.
This case reflects the ongoing challenges faced by plaintiffs in employment discrimination litigation, where establishing discriminatory intent often requires substantial evidence beyond the mere fact that an adverse employment action occurred. Courts require plaintiffs to present evidence that would allow a reasonable jury to conclude that discrimination or retaliation was a motivating factor in the employer's decision.
The ruling also demonstrates the high evidentiary burden plaintiffs face in overcoming summary judgment motions in employment cases. Even when discrimination claims survive initial motions to dismiss, plaintiffs must ultimately present concrete evidence of discriminatory intent or retaliatory motive to proceed to trial.
For municipal employers and law enforcement agencies, the decision reinforces the importance of documenting legitimate business reasons for personnel decisions and maintaining consistent application of employment policies. The case serves as a reminder that while discrimination claims against public employers can proceed under multiple federal statutes, plaintiffs must still meet established evidentiary standards to survive summary judgment and proceed to trial.