United States Court of Appeals for the Eleventh Circuit
664 F.3d 865 (2011)
Jennifer Keeton (plaintiff) was a student in the counselor education program at Augusta State University (the University) (defendant). Students had to complete the program to obtain a master’s degree in school counseling. Keeton was a Christian who believed that homosexuality was immoral. Keeton told her professors and classmates that she believed gay, lesbian, bisexual, transgender, and queer/questioning (GLBTQ) individuals suffered from identity confusion. Keeton stated that she would attempt to convert students from homosexual to heterosexual. Keeton also stated that she would tell students that it is not okay and is morally wrong to be gay. Keeton said she would attempt to change the student’s behavior to comply with these views. The University directed Keeton to comply with a remediation plan to address her ability to serve as a multiculturally competent counselor, specifically with regard to the GLBTQ population. The University required Keeton to consent to the remediation plan before she was eligible to participate in the program’s clinical practicum. The University determined that Keeton’s statements indicated an unwillingness to comply with the American Counseling Association’s (ACA) Code of Ethics. The ACA Code of Ethics prohibited counselors from imposing personal values on clients and required counselors to respect the dignity and diversity of clients. The University was required to adopt and teach the Code of Ethics to be accredited by the Council for Accreditation of Counseling and Related Educational Programs. Keeton sued the University, alleging violations of her free-speech and free-exercise rights under the First Amendment. Keeton also alleged that the University retaliated against her by requiring her to participate in the remediation plan based on her prior statements. Keeton requested a preliminary injunction to prevent the University from dismissing her if she did not complete the remediation plan. The district court denied the preliminary injunction, and Keeton appealed to the United States Court of Appeals for the Eleventh Circuit.
Rule of Law
Holding and Reasoning (Barkett, J.)
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