Hendrix v. DeKalb County Board of Education, 678 F. App'x 398

Hendrix, a DeKalb County teacher and elected county commissioner, voted in March 2011 against the school board’s requested land purchase.
Hendrix alleges that after the vote the Board and former Director of Schools Mark Willoughby retaliated against him, including by not hiring him as Supervisor of Attendance in June 2013.
Hendrix sued under 42 U.S.C. § 1983 in May 2014 claiming First Amendment retaliation; the district court granted summary judgment for defendants.
The court applied a one-year statute of limitations, so only the June 2013 non‑hiring fell within the limitations period. Hendrix did not contest the limitations ruling on appeal and thereby waived earlier claims.
Willoughby selected another qualified candidate (Reeder) because Reeder had prior attendance‑supervisor experience; Willoughby stated he would not have hired Hendrix due to Hendrix’s own attendance problems.
The record includes Hendrix’s admitted improper sick‑leave use, two discipline events (a three‑day suspension and a written reprimand), and testimony that does not link Willoughby’s decision to Hendrix’s vote.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hendrix established causation for a First Amendment retaliation claim based on a March 2011 vote and a June 2013 adverse action	The 27‑month gap can be coupled with other circumstantial evidence to show causation	The temporal gap is too long and there is no other evidence connecting the vote to the hiring decision	Court held causation not established; temporal gap plus lack of evidence defeats claim
Whether claims predating May 2013 are timely	Hendrix did not contest timeliness on appeal	Defendants argued claims before May 2013 are time‑barred by a one‑year statute of limitations	Court treated pre‑May 2013 claims as waived / time‑barred
Whether Willoughby’s stated nondiscriminatory reasons for hiring are pretextual	Hendrix contends retaliation motivated decision (implied pretext)	Willoughby gave nondiscriminatory reasons (selected more experienced candidate; Hendrix’s attendance issues) supported by record	Court found defendants’ explanations supported by evidence; no showing of pretext
Whether temporal proximity alone can suffice to show causation	Hendrix relied on temporal proximity plus alleged other conduct	Defendants argued temporal proximity alone is insufficient given length and record	Court held temporal proximity here insufficient without additional evidence of retaliatory motive

V & M Star Steel v. Centimark Corp., 678 F.3d 459 (6th Cir.) (summary judgment review standard)
Thaddeus‑X v. Blatter, 175 F.3d 378 (6th Cir.) (elements for First Amendment retaliation claim)
Dye v. Office of the Racing Comm’n, 702 F.3d 286 (6th Cir.) (more than two‑year lapse insufficient for temporal‑proximity causation)
Vereecke v. Huron Valley Sch. Dist., 609 F.3d 392 (6th Cir.) (temporal proximity insufficient given totality of circumstances)
Mickey v. Zeidler Tool & Die Co., 516 F.3d 516 (6th Cir.) (temporal proximity plus other evidence can establish causation)