Meade v. Moraine Valley Community College

770 F.3d 680 (2014)

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Meade v. Moraine Valley Community College

United States Court of Appeals for the Seventh Circuit
770 F.3d 680 (2014)

Facts

Robin Meade (plaintiff), an adjunct professor at Moraine Valley Community College (MVCC) (defendant), was terminated after writing a letter expressing harsh criticism of MVCC’s treatment of adjunct professors. Meade was head of the adjunct-faculty union and sent the letter on behalf of the union, using its official letterhead. The letter was sent to the League for Innovation in the Community College (LICC), an organization that included 800 member institutions and 160 corporate partners. MVCC had asked Meade and other union leaders to submit letters expressing support for its reapplication for the LICC board. In her letter, Meade accused MVCC of treating adjuncts as a disposable resource and a lower class of people. Meade expressed concerns over how this treatment would affect students, alluding to an MVCC policy that prohibited adjuncts from working hourly and tutoring students outside of class. Meade also charged MVCC with underpaying adjuncts and denying them proper benefits. MVCC terminated Meade’s contract after getting hold of the letter, explaining that it was irresponsible, rife with falsehoods, and not in the best interests of the university. Meade filed suit, alleging that she was terminated in retaliation for exercising her First Amendment right to free speech. A federal district court granted MVCC’s motion to dismiss for failure to state a claim, finding that Meade’s speech was not protected. Meade appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Wood, C.J.)

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