Keefe v. Adams

840 F.3d 523 (2016)

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Keefe v. Adams

United States Court of Appeals for the Eighth Circuit
840 F.3d 523 (2016)

  • Written by Rose VanHofwegen, JD

Facts

Craig Keefe (plaintiff) posted unprofessional comments about other students in a clinical nursing program on his Facebook page. One comment said he “was going to take this electric pencil sharpener in this class and give someone a hemopneumothorax with it.” Two other students complained, and one said she no longer felt comfortable working with Keefe. Keefe’s instructor forwarded the posts to the director of nursing, who reviewed them and met with Keefe and the dean of students. Keefe said his page had been hacked and had a lot of jokes. The director concluded that she could not teach Keefe the professionalism required under the Nurses Association Code of Ethics, which was a required part of the associate degree nursing program curriculum, and dismissed him effective the end of the semester. Keefe appealed unsuccessfully to the school’s vice president, then sued several of the Central Lakes College Administrators (defendants) for violating his First Amendment and due-process rights. The trial court granted summary judgment against Keefe and he appealed, arguing that he made his comments on the internet, entirely outside of and unrelated to any class, and without violating any rules.

Rule of Law

Issue

Holding and Reasoning (Loken, J.)

Concurrence/Dissent (Kelly, J.)

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