Dorothy King v. Virginia Betts, 354 S.W.3d 691

Nurse Battle objected to MTMHI's night locker policy for medication administration; policy shifted duties to nurses with on-call pharmacist support
MTMHI implemented night locker by removing pharmacists from night/weekend shifts but required on-call coverage and after-hours med access via night locker
MTMHI provided training, resources, and policies to address nurses' safety and licensing concerns; Board of Nursing and Board of Pharmacy reviewed the policy
Battle and King sued MTMHI and related officials in Davidson County Chancery Court under 42 U.S.C. § 1983 alleging First Amendment retaliation and a hostile work environment
Trial court granted summary judgment and judgment on the pleadings; Court of Appeals reversed on immunity and retaliation claims; Supreme Court granted discretionary review
Court held MTMHI defendants entitled to qualified immunity; Battle failed to show clearly established right or adverse action warranting relief

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Battle's criticisms concerned a matter of public concern	Battle’s statements about patient safety and policy impacts public welfare	Speech was primarily personal commentary about job duties and licensing	Speech involved matters of public concern
Whether the right to publicly criticize the night locker policy was clearly established	Right was clearly established at time of conduct	Right not clearly established given mixed personal/public speech	Right not clearly established; immunity applied
Whether MTMHI defendants took adverse employment actions against Battle	Multiple actions were retaliatory and chilled speech	Actions were de minimis or non-retaliatory	No material adverse employment action established; no §1983 retaliation
Whether qualified immunity should be affirmed given posture of record	Defendants violated clearly established rights	Qualified immunity applies; no clearly established violation	Defendants entitled to qualified immunity
Role of state courts in §1983 with qualified immunity in Tennessee; standards applied	State-law procedures should govern immunity analysis	Saucier/Pearson framework applies; federal standards prevail	Apply federal qualified-immunity analysis within state-court §1983 action

Harlow v. Fitzgerald, 457 U.S. 800 (1982) (establishes two-step qualified immunity analysis (now flexible after Pearson))
Anderson v. Creighton, 483 U.S. 635 (1987) (fact-specific approach to clearly established rights)
Saucier v. Katz, 533 U.S. 194 (2001) (established two-step sequence for qualified immunity (clarity later flexible))
Pearson v. Callahan, 555 U.S. 223 (2009) (flexible approach to prongs; court may address prongs in any order)
Bd. of County Comm’rs v. Umbehr, 518 U.S. 668 (1996) (government employee retaliation rights context; general protection of speech)
Garcetti v. Ceballos, 547 U.S. 410 (2006) (speech by public employee evaluated for public concern; employer interests)
Connick v. Myers, 461 U.S. 138 (1983) (public concern test for employee speech balancing content and context)
Waters v. Churchill, 511 U.S. 661 (1994) (limits on government employer restrictions on speech in workplace)
Hed v. Creighton, 483 U.S. 639 (1987) (clarifies clearly established standard requires similar circumstances)
Hope v. Pelzer, 536 U.S. 730 (2002) (clarity of law assessment; not liable for subsequent developments)
Mitchell v. Forsyth, 472 U.S. 511 (1985) (establishes public official immunity framework; burden on plaintiff)