Eckerman v. Tennessee Department of Safety, 636 F.3d 202

Eckerman, a Tennessee Highway Patrol lieutenant, was demoted to sergeant on December 6, 2006 after an internal affairs investigation.
Judge Carter-Ball of the Tennessee Civil Service Commission later reversed the demotion and reinstated Eckerman to lieutenant in 2008, finding no rule violations and that the demotion was not justified.
Eckerman filed this federal action on June 11, 2007, alleging First and Fourteenth Amendment retaliation based on political affiliation and prior federal litigation against the Department of Safety.
The district court granted summary judgment to defendants, concluding Eckerman failed to show the demotion was caused by protected activity rather than legitimate nonpolitical reasons.
The panel reversed in part, concluding res judicata and Judge Carter-Ball’s findings in the administrative proceeding precluded relitigation of certain facts and that remand for trial was appropriate on remaining issues.
The case proceeded to remand for trial on material issues of fact and any unresolved legal defenses, with Eleventh Amendment considerations addressed against official-capacity claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Eckerman's political affiliation protected conduct and a motivating factor for the demotion?	Eckerman's protected political activity substantially influenced the demotion.	Demotion based on nonpolitical, legitimate investigative findings; no causation shown.	Remanded; triable issues remain on causation and motivation.
Does res judicata from the Civil Service Commission decision bar relitigation of facts?	Carter-Ball findings undermine the proffered nonpolitical justification.	Administrative findings should be treated as non-preclusive in federal court.	Carter-Ball findings are conclusive; otherwise, remand for trial.
Did the district court err in granting summary judgment on the retaliation claim?	Evidence supports a 'but-for' causation link between protected conduct and demotion.	Evidence supports legitimate nonpolitical reasons; no triable issue on causation.	Reversed in part; remanded for trial on material facts.
Are official-capacity or Eleventh Amendment defenses properly resolved?	Eleventh Amendment immunity does not bar claims in this context.	Official-capacity claims are barred by Eleventh Amendment immunity.	Affirmed with respect to official-capacity claims; remand for remaining issues.

Rutan v. Repub. Party of Ill., 497 U.S. 62 (U.S. 1990) (political considerations and public employment limits; protected conduct restrictions)
Thaddeus-X v. Blatter, 575 F.3d 389 (6th Cir. 1999) (First Amendment retaliation framework (en banc) for protected activity)
Sowards v. Loudon Cnty., 203 F.3d 426 (6th Cir. 2000) (causal-relation burden-shifting in retaliation cases)
Bowman v. Shawnee State Univ., 220 F.3d 456 (6th Cir. 2000) (non-quantum de minimis adverse actions; pattern evidence relevance)
Kocsis v. Multi-Care Mgmt., Inc., 97 F.3d 876 (6th Cir. 1996) (definition of adverse employment actions in retaliation context)
Jirau-Bernal v. Agrait, 37 F.3d 1 (1st Cir. 1994) (prelitigation procedural considerations in retaliation cases)
Univ. of Tenn. v. Elliott, 478 U.S. 788 (1986) (administrative findings and federal preemption; preclusive effect)
Drummond v. Comm'r of Soc. Sec., 126 F.3d 837 (6th Cir. 1997) (administrative-law preclusion principles in federal cases)