William Ashford v. Univ. of Mich., 89 F.4th 960

William Ashford, a UM-Dearborn police officer, became concerned about his department's handling of a student's sexual assault allegations against a professor in 2019.
After internal efforts, Ashford spoke to a reporter, sharing concerns about a possible cover-up, which led to a published newspaper article.
Ashford was not formally disciplined at UM-D prior to this incident and did not receive training on policies about public statements.
UM-D initiated an internal investigation into Ashford's actions, ultimately suspending him for ten days without pay for allegedly divulging unauthorized information.
Ashford sued the university and officials under 42 U.S.C. § 1983, alleging First Amendment retaliation, seeking damages and removal of the suspension from his record.
On interlocutory appeal, the university and officials argued sovereign and qualified immunity, after the district court denied summary judgment on those bases.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sovereign immunity bars Ashford’s claims for relief	Seeks prospective relief (injunction/expungement), not damages	Sovereign immunity bars all claims against state entities	Sovereign immunity does not bar suit for prospective relief
Whether expunging disciplinary records is prospective relief	Expungement is forward-looking, to remedy ongoing harm	Argues it is retrospective and thus barred	Expungement deemed prospective; claim may proceed
Whether Ashford’s speech was protected by the First Amendment	Spoke as a private citizen on matter of public concern	Ashford acted in official capacity, leaking confidential info	Ashford’s speech was protected, as it was outside official duties
Whether qualified immunity shields the officers	Officials violated clearly established rights by retaliating	No clearly established right in this specific police context	Qualified immunity denied; rights were clearly established

Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (Sovereign immunity bars certain suits against states)
Will v. Mich. Dep't of State Police, 491 U.S. 58 (State officials in their official capacities are generally immune)
Ex parte Young, 209 U.S. 123 (Sovereign immunity does not bar suits for prospective relief against state officers)
Connick v. Myers, 461 U.S. 138 (Sets standard for public concern test in public employee speech)
Garcetti v. Ceballos, 547 U.S. 410 (Speech pursuant to official duties is not protected citizen speech)
Lane v. Franks, 573 U.S. 228 (Clarifies protected speech for public employees)
Saucier v. Katz, 533 U.S. 194 (Qualified immunity two-step test)
Edelman v. Jordan, 415 U.S. 651 (Prospective vs. retrospective relief in immunity)