Opinion

Lynda Gaines v. E. Casey Wardynski

  • 871 F.3d 1203
  • 42 I.E.R. Cas. (BNA) 412
  • 2017 U.S. App. LEXIS 18276
  • 2017 WL 4173625
Court
Court of Appeals for the Eleventh Circuit
Filed
Sep 21, 2017
Status
Published
Author
Jordan
On the bench
Jordan, Carnes, Vinson
Nature of suit
NEW
Cited by
130 cases
Authority
More cited than 13.5%

explaining these are rare situations when constitutional provision is “so clear and the conduct so bad that case law is not needed to establish that the conduct cannot be lawful” (citation omitted)

How later courts described this case

  • explaining these are rare situations when constitutional provision is “so clear and the conduct so bad that case law is not needed to establish that the conduct cannot be lawful” (citation omitted)
  • granting qualified immunity to Superin- tendent of school district, ruling that any prohibition against de- fendant denying teacher a promotion based on a family member’s public criticisms of the school district was based on “First Amend- ment principles at a high level of generality” and, thus, not clearly established
  • holding that, for purposes of qualified immunity, it is the plaintiff’s burden to show 22 that the defendant violated a constitutional right that was clearly established
  • holding that, for purposes of qualified immunity, it is the plaintiff’s burden to show that the defendant violated a constitutional right that was clearly established

Written by the judges who cited it.

The opinion

JORDAN, Circuit Judge,

concurring.

In my view, the constitutional right to freedom of intimate association, whether seen as a pure or hybrid First Amendment right, see Roberts v. United States Jaycees, 468 U.S. 609, 618-20 , 104 S.Ct. 3244 , 82 L.Ed.2d 462 (1984), protects a public employee from adverse treatment based on the speech of a close relative or family member. See Adler v. Pataki, 185 F.3d 35 , 41-45 (2nd Cir. 1999); Adkins v. Bd. of Education, 982 F.2d 952 , 955-56 (6th Cir. *1215 1993); Lewis v. Eufaula City Bd. of Education, 922 F.Supp.2d 1291, 1302-03 (M.D. Ala. 2012). See also Collin O’Connor Udell, Intimate Association: Resurrecting a Hybrid Right, 7 Tex. J. Women & Law 231, 284-85 (1998). Nevertheless, I concur in the court’s opinion and qualified immunity-analysis because no cases from the Supreme Court, the Eleventh Circuit, or the Alabama Supreme Court have so far come to that conclusion.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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