Employment — Public employment; freedom of speech

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U.S. Court of Appeals For the Seventh Circuit

Civil

Employment: Public employment; freedom of speech

Where the president of a public university’s faculty union was terminated for writing a letter criticizing the university’s treatment of adjunct faculty, summary judgment was improperly granted to the university on the employee’s First Amendment claim.

“The content of Meade’s letter places it squarely among matters that are of public concern. The district court thus erred in concluding that her speech was not constitutionally protected. Because it resolved the case at that point, the court did not address the other two issues her case raises: whether the speech was a substantial or motivating factor in the retaliatory action, and whether the defendant can show that it would have taken the same action without the existence of the protected speech. See Chaklos, 560 F.3d at 711. We think it best for the district court to have the first look at those issues on remand.”

Reversed and Remanded.

14-1217 Meade v. Moraine Valley Community College

Appeal from the United States District Court for the Northern District of Illinois, Der-Yeghiayan, J., Wood, J.

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