Jeanne Hedgepeth v. James Britton, 24-1427

Jeanne Hedgepeth, a public high school teacher in Illinois, had a prior disciplinary record for classroom profanity and received explicit warnings that future misconduct could result in termination.
In 2020, Hedgepeth posted comments and memes about the George Floyd protests on her private Facebook account, viewed predominantly by former students.
Her posts were widely criticized as inflammatory and prompted significant complaints from students, parents, colleagues, and extensive media coverage, causing disruption at her school.
The school district cited disruption, violation of multiple employment and decorum policies, and her prior disciplinary history as the basis for her termination.
Hedgepeth challenged her firing in federal court under 42 U.S.C. § 1983, asserting her posts were protected by the First Amendment. The district court granted summary judgment to the district, and Hedgepeth appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hedgepeth’s speech was protected	Speech on public concern (protests/race); speech as citizen	Disruption justified discipline; speech caused real harm to school function	District’s interest outweighs Hedgepeth’s speech interest
Justification for termination (disruption)	No actual disruption, posts were jokes/public debate	Substantial disruption: complaints, media scrutiny, and prior misconduct	Disruption was real, significant, and justified termination
Speech’s private/personal nature	Private account, not self-identified as PHS teacher	Audience was predominantly PHS community; posts inevitably publicized	Privacy settings insufficient; posts foreseeably circulated
“Heckler’s veto” by public response	Termination due to public outcry suppresses dissent	Community are school stakeholders, not outsiders with veto power	Community reaction is valid employer consideration

Pickering v. Bd. of Ed. of Twp. High Sch. Dist. 205, 391 U.S. 563 (1968) (establishing balancing test for public employee speech versus employer’s interest)
Garcetti v. Ceballos, 547 U.S. 410 (2006) (public employees’ speech as citizens on matters of public concern is protected)
Connick v. Myers, 461 U.S. 138 (1983) (differentiating private grievances from matters of public concern in public employment)
Rankin v. McPherson, 483 U.S. 378 (1987) (balancing employer interests with public employee speech on controversial topics)
Craig v. Rich Twp. High Sch. Dist. 227, 736 F.3d 1110 (7th Cir. 2013) (context and disruption required for discipline of teachers over out-of-class speech)