McLaughlin v. Tilendis

John Steele and James McLaughlin (plaintiffs) were employed as probationary teachers by a public-school district in Cook County, Illinois. The district did not rehire Steele for a second year of teaching and dismissed McLaughlin before the end of his second school year. Steele and McLaughlin alleged that the school district had ended their employment because Steele and McLaughlin were members of Local 1663 of the American Federation of Teachers, AFL-CIO (the teachers’ union). There was no evidence that Steele or McLaughlin had ever engaged in any strikes or illegal picketing as members of the teachers’ union. Steele and McLaughlin sued district superintendent Albert Tilendis and members of the district’s board of education (the district officials) (defendants), seeking $100,000 each for an alleged violation of their First Amendment rights of free association. The district officials moved to dismiss the complaint, and the district court granted the motion after finding that Steele and McLaughlin had no First Amendment rights to form or join a labor union. The court stated that unions might engage in strikes or other activity that could affect the government’s ability to function and noted that courts should not interfere with the government’s discretion in choosing how to handle its relations with unions and their members. Steele and McLaughlin appealed to the United States Court of Appeals for the Seventh Circuit.