Mt. Healthy City Board of Education v. Doyle: Facts of the Case

2012-10-30 22:14:41 by admin

Mt. Healthy City Board of Education v. Doyle

Mt. Healthy City Board of Education v. Doyle: The Court’s Ruling

The dispute arose when a nontenured Ohio high school teacher, Doyle, sent a local radio station a copy of his principal’s memo about a school dress code and included his own opinions. Doyle was employed under a series of one- and two-year teaching Contracts between 1966 and 1971. Elected president of the teachers association in 1970, Doyle sought to expand direct negotiations between the association and the school board. During the same year, Doyle engaged in an argument with another teacher who slapped him, resulting in their both being suspended for a day. Shortly thereafter, several teachers staged a walkout to protest the suspensions.

On other occasions, Doyle became involved in an argument with school cafeteria employees over the amount of spaghetti he was served. In a disciplinary report, the board noted that Doyle referred to students as “sons of bitches” and made an obscene gesture to two girls after they failed to obey commands he gave in his capacity as cafeteria supervisor.

The board said that Doyle conducted himself in a nonprofessional manner on several occasions, leading to its recommendation that his contract not be renewed. Doyle later apologized to the principal for contacting the radio station without discussing the policy with administrators. When he asked for reasons for the nonrenewal of his contract, board officials told Doyle that he demonstrated a lack of tact in handling professional matters; used obscene gestures to correct students in the cafeteria, resulting in their discomfort; and notified the local radio station about the board’s suggestions of an appropriate dress code for professional staff.

In response to the board’s action, Doyle filed suit, alleging that it violated his First Amendment protected free speech rights. A federal trial court in Ohio, affirmed by the Sixth Circuit, was of the opinion that Doyle’s telephone call to the radio station was protected First Amendment speech and that it played a substantial part in the nonrenewal of his contract. The court awarded Doyle $5,158 in back pay and reinstatement, even though he had accepted another job in a different school system paying $2,000 less.