Lane v. Franks
Lane v. Franks, 573 U.S. 228, is a U.S. Supreme Court case involving public employee's freedom of speech rights. Edward Lane sued Steve Franks for unfairly firing him, out of retaliation for sworn testimony Lane gave during a federal fraud case. United States Court of Appeals for [the Eleventh Circuit|The Eleventh Circuit] originally ruled in favor of Franks, “denying first amendment protection to subpoenaed testimony”. The case was argued before the Supreme Court on April 28, 2014. The case was decided on June 19, 2014.
The Supreme Court sided with Lane that he was not responsible for something he said during a federal trial. However, the court could not award damages, because Frank's qualified immunity protected him from being sued in his personal capacity. The case is an important vote of confidence from the Supreme Court about governmental employees not being held responsible for speech that is made as a public citizen on a matter of public concern. It is in line with the Pickering v. Board of Education ruling of 1968.
Background
Edward Lane accepted a role at Central Alabama Community College in 2006, as the director of Community Intensive Training for Youth. Lane proceeded to terminate Suzanne Schmitz. Schmitz was a state representative and on the programs payroll, despite not performing any duties. Lane was then subpoenaed to testify “regarding the events that led to his terminating Schmitz” in two federal trials for fraud. In 2009 after the conclusion of the trials Steve Franks, the CACC president, terminated 29 employees.Lane was among the employees that got termination letters. Franks rescinded 27 of the 29 terminations, but two, including Lane's were not rescinded. Lane then sued Franks in “federal district court and alleged that his termination from the CITY program was in retaliation for his testimony against Schmitz and therefore violated his First Amendment to [the United States Constitution|First Amendment] right to free speech. Lane sued Franks in his official and private capacities as the president of CACC.
District Court and Circuit Court rulings
The Federal District Court for the Northern District of Alabama ruled on behalf of Franks. Citing that because Lane learned of the information on the job he was not protected as a citizen on a matter of public concern. They also ruled that Franks was protected because he had qualified immunity. The Eleventh Circuit Court of Appeals affirmed the district court’s decision.Supreme Court ruling
“The critical question is whether the speech at issue is itself ordinarily within the scope of an employee’s duties, not whether it merely concerns those duties. Corruption in a public program and misuse of state funds involve matter of significant public concern; the form and context of the speech, sworn testimony in a judicial proceeding, fortify that conclusion”.In a unanimous decision on behalf of Franks, the court affirmed in part, reversed in part, and remanded in part, for further judicial ruling. The court said that Lane's speech was protected under the first amendment. However, “previous precedent, specifically Morris v. Crow, had held that public employee testimony was unprotected speech, and thus when Franks fired Lane, he was not violating a clearly established constitutional right”.
Since that is the case Franks was entitled to qualified immunity, so the Supreme Court affirmed the Eleventh Circuit’s ruling about “claims against Franks in his individual capacity”. The court remanded the case for further proceedings dealing with Frank's defense of sovereign immunity in his official capacities. This ruling does chip away at the precedent set by the Supreme Courts ruling in Garcetti v. Ceballos, just eight years earlier.