Joseph Little v. City of North Miami
United States Court of Appeals for the Eleventh Circuit
805 F.2d 962 (1986)
- Written by Mike Begovic, JD
Facts
Joseph Little (plaintiff) was a law professor at the University of Florida. Little, a Florida bar member, represented a group called the Florida Defenders of the Environment in two state civil cases on a pro bono basis and with approval from the university. The City of North Miami (defendant) was an intervening party in one of the lawsuits, a state court civil action that involved the correctness of state appropriation of land owned by the city. North Miami’s city council adopted a resolution that publicly censured Little, alleging that, as a law professor, he was using state funds to represent a private party in an action against the city. The resolution was read aloud at a city council meeting and eventually circulated to the university and state legislature. Little did not receive notice of the resolution or an opportunity to challenge it. The resolution led to an investigation, but Little remained employed as a law professor. Little filed a suit against North Miami, council members, and the mayor (defendants) under 42 U.S.C. § 1983, which allowed individuals to sue government officials for violations of constitutional rights. The complaint alleged that Little suffered violations of his First Amendment right of free speech and Fourteenth Amendment right of due process. A district court dismissed the claims without prejudice. In evaluating Little’s First Amendment claim, the district court found that the city ordinance did not have the force of state law required for 42 U.S.C. § 1983 claims. With respect to Little’s due-process claim, the district court found that Little had only suffered harm to his reputation, because he remained employed with the university. Little appealed, arguing that his business reputation constituted a protected property interest.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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