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Manley v. Law

United States Court of Appeals, Seventh Circuit

May 10, 2018

Claudia Manley and Noel Manley, Plaintiffs-Appellants,
Bruce Law and Hinsdale Township High School District 86, Defendants-Appellees.

          Argued October 24, 2017

          Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 15-CV-7499 - Edmond E. Chang, Judge.

          Before Easterbrook, Rovner, and Hamilton, Circuit Judges.

          Hamilton, Circuit Judge.

         American politics is not for the thin-skinned. In this case, a dispute between an elected school board member and a student outside a high school play escalated quickly. The school board launched an investigation into the board member's alleged bullying of the student. The board member and her husband filed this lawsuit, originally to try to stop the investigation. After that did not work, the plaintiffs asserted that the school board and superintendent violated their federal constitutional rights by conducting the investigation and publicly criticizing the board member for her handling of the dispute with the student. The Due Process Clause of the Fourteenth Amendment, plaintiffs tell us, protects their emotional well-being and entitles them to feel that the government treated them fairly. We affirm the district court's grant of summary judgment dismissing the case.

         I. Factual and Procedural Background

         Because the plaintiffs appeal the grant of summary judgment against them, we view the facts in the light reasonably most favorable to them, giving them the benefit of all inferences drawn from the evidence in the record. Brunson v. Murray, 843 F.3d 698, 701 (7th Cir. 2016). This does not mean, however, that we vouch for the objective truth of all the facts presented. Id.

         Plaintiff Claudia Manley was a member of the school board for Hinsdale Township High School District 86 in DuPage County, Illinois. In the winter of 2015, the district was preparing for a contested election in April for three school board seats. Manley was not up for reelection, but her allies on the board were. On the evening of March 12, 2015, Manley got into a verbal altercation with a student who was leaf- letting for Manley's political opponents outside a high school play. Manley insisted that the leafletting violated school board policy.

         The altercation between Manley and the student sparked a wider controversy. The student accused Manley of bullying, and a wave of support for the student crashed against Manley. The night of the incident, the student's parents called Manley and left her several voicemails. When those messages were not returned, the student and her parents pursued a public campaign to embarrass Manley that included online petitions, newspaper articles, and comments at public meetings, all aimed at removing Manley from her position on the board. As the pressure increased, the school district's superintendent, defendant Bruce Law, began an investigation into Manley's behavior outside the play. After Law announced the investigation, Manley and her husband Noel filed suit in state court to enjoin the investigation.

         No injunction was issued, and the investigation ended with no change in Manley's legal rights or legal status. Manley has alleged bias and unfairness on the part of the board, the superintendent, and his investigator, but the investigation ended with nothing more than a public report finding that Manley violated a board policy calling for "mutual respect, civility and orderly conduct" at school events. The board adopted the investigative report's findings and formally admonished Manley for violating the board's policy and for overstepping her authority in attempting to enforce unilaterally the district's leafletting policy. Manley is no longer on the school board, but not because of district action against her. She decided not to seek reelection in 2017.

         As these events unfolded, the Manleys' lawsuit evolved in state court from an action to enjoin the investigation to a suit seeking a declaratory judgment that numerous alleged procedural irregularities violated state and local law. The amended complaint, however, also sought damages that "might, for example, be awarded pursuant to the remedies provided by 42 U.S.C. § 1983."

         Based on this reference to relief under a federal statute for alleged federal constitutional violations, the defendants removed the suit to federal court. The plaintiffs fought to support their federal claims. Both sides moved for summary judgment, and the district court granted the defendants' motion. The court found that the plaintiffs failed to offer evidence of a required element of a due process claim: the deprivation of a constitutionally recognized liberty or property interest. The district court also found that Noel Manley lacked standing to assert his federal claims. With no remaining questions of federal law and no diversity of citizenship between the parties, the district court declined to exercise supplemental jurisdiction over the plaintiffs' state law claims through 28 U.S.C. § 1367, remanding the remaining claims to state court. Plaintiffs have appealed. We review de novo the district court's grant of summary judgment. Brunson, 843 F.3d at 704.

         II. Analysis

         Bitter disagreements and harsh words are not new to American politics. Nearly two centuries ago, Tocqueville wrote that in American politics, "electioneering intrigues, the meanness of candidates, and the calumnies of their opponents … are occasions of enmity which occur the oftener, the more frequent elections become." Alexis de Tocqueville, 2 Democracy in America 125 (Henry Reeve ...

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