Waters v. Churchill
United States Supreme Court
511 U.S. 661 (1994)

- Written by Josh Lee, JD
Facts
Cheryl Churchill (plaintiff) and Melanie Perkins-Graham were nurses employed by a public hospital. During a dinner break, Churchill allegedly made negative and inappropriate remarks about the hospital and her supervisors. The hospital investigated and interviewed people who overheard the conversation. These interviews included two trusted hospital employees, whose reliability had been endorsed by three hospital managers. The hospital also interviewed Churchill. Churchill asserted that the statements criticized only hospital policy, which she believed threatened patient care and increased staff shortages. According to reports, Churchill did comment on hospital policy, but she also discouraged an employee from working for a department and undermined management’s authority to another employee. The hospital fired Churchill. Churchill then sued, alleging that her termination violated the First Amendment because she was speaking about matters of public concern. The trial court granted summary judgment to the hospital, and Churchill appealed.
Rule of Law
Issue
Holding and Reasoning (O’Connor, J.)
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