Keefe v. Geanakos

Robert Keefe (plaintiff) headed the English department for the Ipswich Public School System in Massachusetts and taught part-time as a tenured teacher. On the first day of school, Keefe gave a copy of the September 1969 Atlantic Monthly magazine to each student in his senior English class. September was the educational issue of the magazine, and copies had been provided by the school department. Keefe assigned one of the magazine’s scholarly articles as a reading assignment. The article was a discussion on dissent, protest, and radicalism and included several uses of the word motherfucker. During class, Keefe discussed the word’s origin and context and the author’s reason for including it. The word was necessary for the development of the article’s thesis and conclusion. George Geanakos and the other members of the Ipswich School Committee (school committee) (defendants) suspended Keefe for conduct unbecoming and notified Keefe of a dismissal hearing. Keefe filed suit in federal district court, seeking an injunction to stop the dismissal hearing. Keefe argued that his discussion of the Atlantic Monthly article was protected by academic freedom and that the school committee’s sanctions violated his protected liberty interests under the Fourteenth Amendment. The district court ruled in favor of the school committee, and Keefe appealed to the United States Court of Appeals for the First Circuit.