Ashford v. University of Michigan, 2:20-cv-10561

William Ashford, a UM-Dearborn police officer, raised concerns about university mishandling of an alleged sexual assault by a professor.
After unsuccessful attempts to address these with supervisors and internal channels, Ashford spoke with a reporter from The Detroit News, discussing his belief that the case was mishandled/covered up.
Following the article's publication, Ashford admitted to his superiors that he had spoken to the media; his supervisors initiated a professional standards investigation.
Ashford was suspended for ten days without pay for violating department policy by sharing information obtained through his job with the press.
Ashford filed suit under 42 U.S.C. § 1983, claiming First Amendment retaliation and seeking to remove the suspension from his record (prospective relief), as well as damages.
Defendants (university, chief, and vice chancellor) moved for summary judgment, asserting sovereign and qualified immunity; district court denied the motion; defendants appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sovereign immunity bars Ashford's prospective claim	Sovereign immunity does not bar prospective injunctive relief	Sovereign immunity bars any claim for relief, including expungement	Not barred—prospective relief, like record expungement, allowed
Whether Ashford’s speech was protected under the First Amendment	Speech concerned a public matter, outside official duties	Speech was related to job responsibilities, not protected	Protected—speech was on public concern, not job duty
Whether Ashford faced unconstitutional retaliation	He was disciplined because of protected speech	Disciplinary action was for policy violation, not speech	Sufficient evidence of retaliation to proceed to trial
Whether qualified immunity shields defendants	No immunity—right to speak publicly on such issues was clear	Actions did not violate clearly established rights	Not immune—law was clearly established

Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (sovereign immunity principles for state entities)
Garcetti v. Ceballos, 547 U.S. 410 (public employee speech under First Amendment)
Edelman v. Jordan, 415 U.S. 651 (delineates retrospective vs. prospective relief re sovereign immunity)
Connick v. Myers, 461 U.S. 138 (distinguishes public vs. private concern in employee speech)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-part test flexibility)
Kentucky v. Graham, 473 U.S. 159 (official capacity claims are against current officeholders)
Saucier v. Katz, 533 U.S. 194 (steps for qualified immunity analysis)