2012-10-30 22:16:22 by admin
Mt. Healthy City Board of Education v. Doyle: Facts of the Case
On appeal to the Supreme Court, in addition to the free speech claims, the school board raised the issue of Immunity from suits under the Eleventh Amendment to the U.S. Constitution. The Court ruled the board was not entitled to the protection of sovereign Immunity, because it is a political subdivision, not an arm of the state. The Court explained that while local school boards are subject to some guidance from the state board of education and receive state funds, they have extensive power to issue bonds and to levy taxes within specified restrictions of state law.
Turning to the issue of free speech, the Court pointed out that in Board of Regents v. Roth (1972), it ruled that while a nontenured employee may be dismissed without cause, if issues of constitutionally protected free speech play major roles in the termination of their Contracts, they may have grounds for reinstatement. The Court observed that Doyle’s behavior patterns played a major role in the dispute, because he offended other teachers and students.
The Court also acknowledged that in Pickering v. Board of Education of Township High School District 205,Will County (1968), it maintained that the question of free speech issues involves finding a balance between the interests of public school teachers as citizens in commenting on matters of public concern and the interest of the state qua school boards as employers in promoting the efficiency of the public service they provide through their employees.
In its analysis, the Court determined that there were other factors in decisions to grant tenure to or rehire a borderline or marginal teacher such as Doyle, along with the First Amendment claims. The Court thus remanded the dispute for a consideration of whether factors other than the First Amendment issue would have led the board not to renew Doyle’s contract.
On remand, the Sixth Circuit (Doyle, 1982) affirmed that the board demonstrated by a preponderance of the evidence that it would not have renewed Doyle’s contract even if he had not contacted the radio station.