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Coomes v. Edmonds Sch. Dist. No. 15
United States Court of Appeals for the Ninth Circuit
816 F.3d 1255 (2016)
Tristan Coomes (plaintiff) was a middle school teacher in Edmonds School District Number 15 (Edmonds) (defendant). Coomes was the manager of the program at Meadowdale Middle School (Meadowdale) for students with emotional and behavioral disorders, and she taught students placed in this special program. Coomes began expressing complaints and concerns regarding how some students were being delayed in their release into mainstream classes and how others were not pulled from mainstream classes. Coomes sent emails regarding her concerns to teachers and various officials in her chain of command, including Principal Christine Avery and Vice Principal Joe Webster (defendants), and she communicated with parents as well. Indeed, Coomes’s communications and her job description indicated that her duties included communication with administrators and substantial contact with parents. Coomes began to receive negative evaluations and letters from Avery and Webster that criticized her work. An Edmonds superintendent, to whom Coomes complained, agreed to move Coomes to a high school the following year. However, one day while at school, Coomes collapsed to the floor crying uncontrollably and had to take a medical leave of absence for around four months. Coomes opted not to go back to work at Meadowdale, and Coomes’s attorney communicated to Edmonds her claim that she was constructively discharged. Coomes sued Edmonds, alleging, among other claims, that she had experienced retaliation for exercising her First Amendment right to speak on matters of public concern. Edmonds sought summary judgment, which was granted by a federal district court. Coomes appealed.
Rule of Law
Holding and Reasoning (O’Scannlain, J.)
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