By: Derek Hawkins//December 26, 2018//
7th Circuit Court of Appeals
Case Name: Nicole Bogart, et al. v. Vermilion County, Illinois, et al.
Case No.: 18-1719
Officials: WOOD, Chief Judge, and SYKES and SCUDDER, Circuit Judges.
Focus: 1st Amendment Violation
Nicole Bogart, a Democrat, worked as the Financial Resources Director of Vermilion County, Illinois, but her tenure ended when Michael Marron, a Republican, assumed control of the County Board and fired her. She responded by bringing claims under the First Amendment and Equal Protection Clause, alleging that Vermilion County and Marron violated her right of political affiliation and engaged in political retaliation. The district court dismissed the equal protection claim as duplicative of the First Amendment claim, and, after finding that the substantial fiscal and budgetary responsibilities of Bogart’s position fit within the Elrod-Branti exception to political patronage dismissals, granted summary judgment for the defendants on her First Amendment claim. We affirm.
Affirmed