Greene v. Greenwood Public School District, 4:16-cv-00093

Background

Montrell Greene, former superintendent of Greenwood Public School District (GPSD), sued GPSD and three board members after his January 2016 termination, asserting 42 U.S.C. § 1983 claims (procedural and liberty due process) and several state-law claims (defamation, breach of contract, bad-faith breach, etc.).
Greene attached his employment contract, an amendment extending the term, and a January 5, 2016 termination letter stating termination for "cause."
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) (jurisdictional challenge based on failure to pursue chancery-court review under Miss. Code § 37-9-113) and 12(b)(6) (failure to state federal claims).
The chancery court had granted Greene a limited bill of discovery for reasons supporting his termination, but did not explicitly decide whether § 37-9-113 required a superintendent to appeal; Greene did not perfect an appeal to chancery court.
The district court held it had federal-question jurisdiction over Greene's § 1983 claims (exhaustion of state remedies is not required to bring a § 1983 action) but dismissed Greene's federal claims on the merits and declined supplemental jurisdiction over the state-law claims, dismissing them without prejudice.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to file a chancery-court appeal under Miss. Code § 37-9-113 deprives the federal court of subject-matter jurisdiction	Greene argued chancery court proceedings collaterally estopped defendants from raising the § 37-9-113 issue	Defendants argued Greene never litigated or appealed his termination under § 37-9-113 and so the federal court lacks jurisdiction to hear state-review claims	Court: Greene's failure to perfect a § 37-9-113 appeal does not strip federal subject-matter jurisdiction over § 1983 claims; collateral estoppel did not apply because chancery court did not decide § 37-9-113 issue definitively
Whether Greene stated a § 1983 procedural-due-process claim based on denial of a hearing	Greene contended termination without a pre/post-termination hearing violated due process, relying on his employment contract as a property interest	Defendants pointed to Miss. Code § 37-9-59 (superintendents have no statutory right to request a hearing) and argued Greene should have sought chancery review	Court: Dismissed procedural-due-process claim — Greene was not entitled to a hearing under current Mississippi statute, and having not invoked chancery review, he cannot show denial of adequate process
Whether Greene stated a § 1983 liberty-interest (stigma-plus) claim based on defamation from the termination	Greene alleged the manner of discharge stigmatized and damaged his reputation, impairing future employment	Defendants argued Greene did not identify any false, stigmatizing statements, publicization, or that he sought a name-clearing hearing	Court: Dismissed liberty-interest claim — Greene pleaded only a generalized stigma of discharge and failed to allege the required elements (specific false stigmatizing charges, publication, request and denial of a name-clearing hearing)
Whether a § 1985/ civil-conspiracy claim under § 1983 was properly pleaded	Greene implied conspiracy among board members	Defendants argued no facts pleaded showing class-based, discriminatory animus required by § 1985	Court: Dismissed conspiracy claim — no allegation of racial or other protected class-based animus or requisite facts to state a § 1985 claim

Key Cases Cited

Patsy v. Bd. of Regents of the State of Fla., 457 U.S. 496 (U.S. 1982) (exhaustion of state remedies not prerequisite to a § 1983 action)
Monroe v. Pape, 365 U.S. 167 (U.S. 1961) (availability of § 1983 remedy regardless of state law remedies)
Roth v. United States, 408 U.S. 564 (U.S. 1972) (property interest for due-process purposes must be a legitimate entitlement under state law)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for Rule 12(b)(6))
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (legal conclusions unsupported by factual allegations will not survive Rule 12(b)(6))
Smith v. Regional Transit Authority, 756 F.3d 340 (5th Cir. 2014) (district court may resolve factual disputes when addressing Rule 12(b)(1) jurisdictional challenges)
Hughes v. City of Garland, 204 F.3d 223 (5th Cir. 2000) (elements of stigma-plus liberty-interest claim)