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

Mt. Healthy City School District Board of Education v. Doyle
Supreme Court of the United States
Argued November 3, 1976 Decided January 11, 1977
Full case name	Mt. Healthy City School District Board of Education et al v. Fred Doyle
Docket no.	75-1278
Citations	429 U.S. 274 (more) 97 S. Ct. 568; 50 L. Ed. 2d 471
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	Aff'd in part and vac'd in part, per curiam, 529 F.2d 524 (6th Cir., 1975); certiorari granted, 425 U.S. 933.
Subsequent	Judgement for defendants aff'd, per curiam, 670 F.2d 29 (6th Cir., 1982)
Holding
School district was not an arm of the state and thus could not claim immunity from suit in federal court under Eleventh Amendment; once plaintiff has proved they engaged in activity protected under the First Amendment, government must show by preponderance of evidence that adverse employment action would have occurred for other, permissible reasons. Sixth Circuit vacated and remanded.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Potter Stewart Byron White · Thurgood Marshall Harry Blackmun · Lewis F. Powell Jr. William Rehnquist · John P. Stevens
Case opinion
Majority	Rehnquist, joined by unanimous
Laws applied
U.S. Const. amends. I, XI and XIV

Mt. Healthy City School District Board of Education v. Doyle, 429 U.S. 274 (1977), often shortened to Mt. Healthy v. Doyle, was a unanimous U.S. Supreme Court decision arising from a fired teacher's lawsuit against his former employer, the Mount Healthy City Schools. The Court considered three issues: whether federal-question jurisdiction existed in the case, whether the Eleventh Amendment barred federal lawsuits against school districts, and whether the First and Fourteenth Amendments prevented the district, as a government agency, from firing or otherwise disciplining an employee for constitutionally protected speech on a matter of public concern where the same action might have taken place for other, unprotected activities. Justice William Rehnquist wrote the opinion.

The case was first heard in the Southern District of Ohio. In 1971, Fred Doyle, who had been teaching social studies for five years in the Mount Healthy City Schools, learned his contract had not been renewed, not only denying him tenure but any further employment with the district. The superintendent's letter cited both an incident where he had made an obscene gesture to students and his sharing of a district dress code for teachers with a local radio station as displaying a "lack of tact". He took a position with another district and filed suit under Section 1983, arguing his constitutional rights to free speech had been violated, per the Court's 1967 decision in Pickering v. Board of Education, another case involving an untenured teacher fired for speaking out in the media. After the district court ruled in his favor, the school district appealed to the Sixth Circuit Court of Appeals, which partially vacated the decision in a brief per curiam opinion late in 1975.

The Supreme Court took the case and heard oral argument almost a year later. It handed down its decision early in 1977. On the jurisdictional question, Rehnquist held that although the school district had been created by state law, it was primarily a local entity and thus beyond the reach of the Eleventh Amendment, its first ruling in that area in 86 years.^[1] The Court did not, however, decide the question of whether Doyle had been fired legally, since there were other incidents suggesting he had difficulties in his relationships with students and fellow teachers which the district had introduced into the record. Instead, it remanded the case to the district court, ordering it to require the district to show by a preponderance of evidence that Doyle would have been fired regardless if he had not contacted the radio station. The school district was later able to do so, and in 1982 the Sixth Circuit upheld that decision.

The case introduced what has since become known as the "Mt. Healthy test" into similar cases that follow the Pickering line in asserting the First Amendment rights of public employees where the employer claims other, unprotected conduct motivated the adverse action, a two-prong process that shifts the burden of proof from plaintiff to defendant in the course of the action. First, the plaintiff must prove that the activity they were allegedly disciplined for was indeed protected speech. The defendant must then show by a preponderance that the adverse action would have occurred if the protected activity had never happened. This has been criticized as allowing public employers a way to circumvent restrictions on taking adverse action against whistleblowers, and more generally as incompatible with the underlying principles of tort law. The test has also been expanded into mixed motive discrimination cases in employment law.