Matthews v. City of New York

779 F.3d 167 (2015)

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Matthews v. City of New York

United States Court of Appeals for the Second Circuit
779 F.3d 167 (2015)

Facts

Craig Matthews (plaintiff) was a police officer who worked for New York City (the city) (defendant). Matthews’s duties included responding to 911 calls, patrolling, transporting prisoners, and the like. After a quota system was established in Matthews’s precinct, along with a point system that awarded points for the issuance of favored summonses and subtracted points for others, Matthews became alarmed. In Matthews’s view, the quota system was causing arrests, stops, and the issuance of summonses that were not justified. Matthews felt that officers were under pressure to forgo their own discretion in such matters in order to fulfill the quota. Therefore, the implementation of the quota system had a negative impact on the relationship between the police and the community. In 2009 Matthews reported that a quota system had been implemented by his supervisors to his commanding officer twice and to another executive officer once. Matthews also reported the quota system to his new commanding officer in 2011. In fact, community members spoke to the same precinct commanders about the quota system. Matthews alleged that for reporting the quota system he had experienced retaliation in the form of tasks assigned as punishments, inability to work overtime or take leave, poor evaluations, and separation from the partner he had had for his entire tenure as an officer. Matthews filed suit, alleging he had been retaliated against because he spoke to commanding officers regarding the quota system. The city moved for summary judgment, which a trial court granted, finding Matthews had not spoken as a private citizen but as a public employee, and therefore, the First Amendment did not protect his comments. Matthews appealed.

Rule of Law

Issue

Holding and Reasoning (Walker, J.)

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