[Doc. 14-1 at 18-20 & nn.6, 7 (citing Pearson v. Callahan, 555 U.S. 223, 241 (2009); Saucier v. Katz, 533 U.S. 194, 201 (2001), modified by Pearson, id.; Randall v. Scott, 610 F.3d 701, 714, 716 (11th Cir. 2010); [Doc. 11 ¶ 47])]. In response, Plaintiff contends that Ragsdale's argument that he could not be held individually liable as a "decisionmaker" fails because the case is only at the pleadings stage and therefore is premature and underdeveloped, [Doc. 15 at 23-24 (citing Crutch v. Lawrence Cnty. Bd. of Educ., No. 3:12-CV-827-PWG, 2012 WL 3030173, at *3 n.4 (N.D. Ala. July 23, 2012))], and because she has pleaded facts alleging that Ragsdale "recommended and advocated" for Plaintiff to be transferred and thus has plausibly pleaded facts showing that he personally participated in the deprivation of Plaintiff's constitutional rights or that there was a causal connection between Ragsdale's activity and the constitutional deprivation, [Doc. 15 at 23-24 (citing Hackett v. Fulton Cnty. Sch. Dist., 238 F. Supp. 2d 1330, 1359 (N.D. Ga. 2002) (Carnes, J.))]. As to the qualified-immunity argument, Plaintiff contends that her pleadings show that Ragsdale violated her constitutional rights by taking sides in a dispute over religious dogma and by punishing her for what he believed were Buddhist or anti-Christian activities outside of school, [Doc. 11 ¶ 47], and suggests that the answer to whether there was a violation may depend on facts not yet fully developed.

Although the Eleventh Circuit has not extended individual liability to situations in which a governmental authority "rubber stamps" a recommendation, id. at 880, recent caselaw— relying on Staub v. Proctor Hospital, 131 S. Ct. 1186 (2011)-suggests that individual liability is appropriately imposed on an "unlawfully motivated subordinate (the monkey, in the cat's paw fable) under § 1983." Polion v. City of Greensboro, No. 13-0244-WS-M, 2014 WL 2611562, at *15 n.16 (S.D. Ala. June 10, 2014); see also Smith v. Bray, 681 F.3d 888, 899 (7th Cir. 2012) (stating that five other circuits have held that individual liability under § 1983 is appropriate on this basis); Crutch v. Lawrence Cnty. Bd. of Educ., No. 3:12-CV-827-PWG, 2012 WL 3030173, at *3 n.4 (N.D. Ala. July 23, 2012) (mitigating Kamensky's weight of persuasion in light of it being an unpublished opinion based on a summary judgment record). a. Parties' Arguments

The relationship between Title VII and § 1983 differs from the relationship between the ADA and § 1983; "[i]t is well established that plaintiff[s] may assert claims under § 1983 to recover for race discrimination in employment premised upon a violation of the Equal Protection Clause of the Fourteenth Amendment." Crutch v. Lawrence County Bd. of Educ., No. 3:12-cv-0827-PWG, 2012 WL 3042238, at *8 (N.D. Ala. 2012) (citing Crawford v. Carroll, 529 F.3d 961, 970 (11th Cir. 2008)). In Crawford v. Carroll, the Eleventh Circuit outlined the elements of a prima facie case for racial discrimination—the same ones this court already discussed in analyzing Count II—noting that "[t]hese elements also apply to a claim of race discrimination under § 1983 because the analysis of disparate treatment claims under § 1983 is identical to the analysis under Title VII where the facts on which the claims rely are the same."