Mt. Healthy City School District Board of Education v. Doyle

429 U.S. 274 (1977)

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Mt. Healthy City School District Board of Education v. Doyle

United States Supreme Court
429 U.S. 274 (1977)

  • Written by Whitney Kamerzel , JD
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Facts

Fred Doyle (plaintiff) was employed as a teacher by the Mt. Healthy City School Board of Education (the Board) (defendant) for five years. During this time, Doyle was involved in several incidents that showed Doyle’s lack of professionalism, including fighting with teachers, yelling at the cafeteria staff for serving too little pasta, and making obscene gestures toward students. In addition, the Board published a new dress code for teachers, and Doyle called the local radio station to alert the public and criticize it. One month later, when Doyle was up for tenure consideration, the superintendent determined that Doyle and nine other teachers would not be rehired. Doyle received a letter that his firing was due to Doyle’s unprofessionalism, the call to the radio station, and the obscene-gestures incident. Doyle sued the Board under 42 U.S.C. § 1983, and the federal district court found that Doyle’s call to the radio station, which was protected under the First Amendment, played a substantial part in the Board’s decision to fire Doyle, and that Doyle was therefore entitled to reinstatement and backpay. The court of appeals affirmed. The Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Rehnquist, J.)

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