Lane v. Franks
134 S. Ct. 2369
| SCOTUS | 2014Background
- Lane, Director of CITY at CACC, audited CITY expenses and found Schmitz, a state representative on CITY’s payroll, not reporting for work.
- Lane fired Schmitz after warnings and discussions with CITY officials, leading to Schmitz’s federal indictment for mail fraud and theft related to federal funds.
- Lane testified under subpoena about the events that led to Schmitz’s termination; Schmitz was convicted on multiple counts.
- CITY faced significant budget shortfalls; Franks terminated Lane and 28 other CITY employees, later rescinding all but Lane and one other employee.
- Lane sued Franks (individual and official capacities) under 42 U.S.C. §1983 for First Amendment retaliation; District Court granted summary judgment for Franks on immunity grounds, Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lane’s sworn testimony outside his ordinary duties is protected as citizen speech | Lane argues he spoke as a citizen on public concern. | Franks argues Garcetti controls; speech was within job duties. | Yes; protected as citizen speech on public concern. |
| Whether the Pickering-Garcetti framework requires government interest to override citizen speech | Speech should be protected given public-spirited testimony. | Employer interests could justify discipline. | Employer interests insufficient; protections apply. |
| Whether Franks is entitled to qualified immunity for firing Lane | Franks violated clearly established First Amendment rights. | At the time, Eleventh Circuit precedent did not clearly preclude firing. | Franks entitled to qualified immunity. |
| Effect on Burrow’s official-capacity claims and remand | Burrow should be liable in official capacity for retaliation. | Initial disposition was improper on sovereign/immunity grounds. | Reverse as to Burrow; remand for further proceedings. |
Key Cases Cited
- Garcetti v. Ceballos, 547 U.S. 410 (2006) (two-step test; speech as citizen vs. employee)
- Pickering v. Board of Ed. of Township High School Dist. 205, 391 U.S. 563 (1968) (balance public employee and government interests)
- Connick v. Myers, 461 U.S. 138 (1983) (content/form/context test for public concern)
- San Diego v. Roe, 543 U.S. 77 (2004) (public employees as commenters on government policies)
- Mandujano v. United States, 425 U.S. 564 (1976) (testimony under oath; truthful testimony value)
- United States v. Alvarez, 567 U.S. _ (2012) (speech; accuracy not always required for protection)