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

Court Case which took place in 1977

Susie Hooth

on 24 March 2013

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Transcript of Mt. Healthy City School District Board of Education vs. Doyle

Case Details

Argued 11/3/1976 Decided 1/11/1977 Facts Implications for Educators School employee (Doyle) issues:
Obscene gestures to female students
Altercation with another teacher
Arguments with other employees
Referred to other students as "sons of bitches" 1st and 14th Amendment rights


If a public employer can defend itself in a 1st Amendment retaliation claim by proving that it would have made the same decision without the 1st Amendment incident Issues Bench Court ruled Doyle was to be reinstated and given back-pay

2nd Court of appeals upheld previous ruling

Supreme Court reversed ruling in favor of Mt. Healthy School District

Became known as the landmark case, "Mt. Healthy Defense" Holding The employer was able to show the employee would have been terminated even without the 1st Amendment incident.

The employee had to prove the termination was in response to a protected 1st Amendment activity. The employee needed to prove this incident played a "substantial role" in the dismissal. Reasoning As a school employee, one can voice an opinion and cannot be terminated based solely on this act.

However, if he/she is terminated, the employee must prove the dismissal was substantially based on the 1st Amendment act. Put those minds to work! Can a teacher voice an opinion in public regarding school policies? Mt. Healthy City School District
Board of Education vs. Doyle Leslie Sauder
Susie Hooth A memo was given to employees regarding a new dress code. Doyle called a radio station describing the memo and voiced his disapproval. The non-tenured employee's contract came up for
renewal, in which he was not hired back. The employee sued the district claiming their refusal
to rehire violated his 1st and 14th Amendment rights. School board statement, "a notable lack of
tact in handling professional matters
which leaves much doubt as to your
sincerity in establishing good school
relationships." This general statement
was followed by references to the radio
station incident and obscene gesture
incident. Does it make a difference how the opinion was voiced? Can the school waive the 1st Amendment incident and terminate based on previous altercations?
Full transcript