Robin Meade v. Moraine Valley Community Colle
770 F.3d 680
| 7th Cir. | 2014Background
- In Aug. 2013 Robin Meade, president of the Moraine Valley Adjunct Faculty Organization (MVAFO), sent a letter to the League for Innovation in the Community College (LICC) criticizing Moraine Valley Community College’s treatment of adjunct faculty and linking that treatment to student performance concerns.
- Two days after the letter, Moraine Valley terminated Meade and later warned she would be treated as a trespasser if she returned to campus; the termination letter expressly cited Meade’s LICC letter as the reason.
- Meade sued under 42 U.S.C. § 1983 alleging (1) First Amendment retaliation and (2) violation of procedural due process (property interest in her Fall 2013 employment agreement). A state-law claim was dismissed below and not appealed.
- The district court dismissed both federal claims for failure to state a claim, finding the letter was not on a matter of public concern and that Meade lacked a cognizable property interest.
- The Seventh Circuit reviewed de novo, construed the complaint and attachments in Meade’s favor, and remanded, holding the district court erred on both First Amendment and property-interest questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Meade's letter addressed a matter of public concern for First Amendment protection | Meade: letter raised matters of public interest — treatment of adjuncts and effect on student performance | Moraine Valley: letter was a private/personal grievance and not entitled to protection; private communication | Held: Letter addressed matters of public concern (adjunct treatment, student impact); protected speech — district court erred |
| Whether speech was a motivating factor and whether the College would have taken the same action | Meade: termination and trespass warning were retaliatory and motivated by the letter | Moraine Valley: termination was justified by alleged misrepresentations and disruptive rhetoric | Held: Court did not decide on causation/preemption at dismissal; remanded for district court to address whether speech was a substantial/motivating factor and if the College can show same-action defense |
| Whether Meade had a cognizable property interest in her Fall 2013 employment (procedural due process) | Meade: the one-page employment agreement with specific course assignments, dates, and pay created a legitimate expectation of employment for that term | Moraine Valley: at-will status (CBA and general policies) meant no protected property interest | Held: The specified-duration employment terms created a property interest in the Fall 2013 term; district court erred in dismissing the due process claim |
| Whether Meade pled a protected liberty interest via stigmatizing accusations (defamation/stigma-plus) | Meade: termination letter stigmatized her (dishonesty) harming reputation and liberty | Moraine Valley: No such claim pleaded; Paul v. Davis bars generalized reputational interests without more; no publication alleged | Held: Meade failed to plead a protected liberty interest (stigma-plus); claim insufficient |
Key Cases Cited
- Garcetti v. Ceballos, 547 U.S. 410 (statement by public employee pursuant to duties not protected)
- Pickering v. Bd. of Educ., 391 U.S. 563 (public-employee speech on matters of public concern is protected)
- Connick v. Myers, 461 U.S. 138 (test for public concern: content, form, context)
- City of San Diego v. Roe, 543 U.S. 77 (definition of public concern)
- Hostrop v. Bd. of Junior Coll. Dist. No. 515, 471 F.2d 488 (contract term of employment can create property interest)
- Paul v. Davis, 424 U.S. 693 (reputation alone is not a protected liberty or property interest under Fourteenth Amendment)
- Perry v. Sindermann, 408 U.S. 593 (mutually explicit understandings can create entitlement to employment)
- Cromwell v. City of Momence, 713 F.3d 361 (Illinois at-will presumption and sources of property interest)
- Craig v. Rich Twp. High Sch. Dist. 227, 736 F.3d 1110 (speech mixing personal and public concern can be protected)
- Chaklos v. Stevens, 560 F.3d 705 (standards for public-employee retaliation claims)