Mt. Healthy test
| Mt. Healthy City School District Board of Education v. Doyle | |
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| Argued November 3, 1976 Decided January 11, 1977 |
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| Full case name | Mt. Healthy City School District Board of Education et al v. Fred Doyle |
| Docket nos. | 75-1278 |
| Citations | 429 U.S. 274 (more)
97 S.Ct. 568, 50 L.Ed.2d 471
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| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Prior history | Aff'd in part and vac'd in part, per curiam, 529 F. 2d 524 (6th Cir., 1975); certiorari granted, 425 U.S. 933 |
| Subsequent history | Judgement for defendants aff'd, per curiam, 670 F.2d 29 (6th Cir., 1982) |
| Holding | |
| School district was not an arm of the state and thus could not claim immunity from suit in federal court under Eleventh Amendment; once plaintiff has proved they engaged in activity protected under the First Amendment, government must show by preponderance of evidence that adverse employment action would have occurred for other, permissible reasons. Sixth Circuit vacated and remanded. |
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| Court membership | |
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| Case opinions | |
| Majority | Rehnquist, joined by unanimous |
| Laws applied | |
| U.S. Const. amends. I, XI and XIV | |
Mt. Healthy City School District Board of Education v. Doyle, 429 U.S. 274, often shortened to Mt. Healthy v. Doyle, was a unanimous 1977 U.S. Supreme Court decision arising from a fired teacher's lawsuit against his former employer, the Mount Healthy City Schools. The Court considered three issues: whether federal-question jurisdiction existed in the case, whether the Eleventh Amendment barred federal lawsuits against school districts, and whether the First and Fourteenth Amendments prevented the district, as a government agency, from firing or otherwise disciplining an employee for constitutionally protected speech on a matter of public concern where the same action might have taken place for other, unprotected activities. Justice William Rehnquist wrote the opinion.
The case was first heard in the Southern District of Ohio. In 1971, Fred Doyle, who had been teaching social studies for five years in the Mount Healthy City Schools, learned his contract had not been renewed, not only denying him tenure but any further employment with the district. The superintendent's letter cited both an incident where he had made an obscene gesture to students and his sharing of a district dress code for teachers with a local radio station as displaying a "lack of tact". He took a position with another district and filed suit under Section 1983, arguing his constitutional rights to free speech had been violated, per the Court's 1967 decision in Pickering v. Board of Education, another case involving an untenured teacher fired for speaking out in the media. After the district court ruled in his favor, the school district appealed to the Sixth Circuit Court of Appeals, which partially vacated the decision in a brief per curiam opinion late in 1975.
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