![]() Cromley's written annual evaluation of Meints several weeks later was private communication that was not protected speech. Cromley's call to DCFS was protected speech. The court noted that, under this analysis, the parties did not dispute that Ms. ![]() It acknowledged that this analysis requires that, in order to be afforded First Amendment protection, the employee's speech must relate to a matter of public concern and the employee's right to speak out must outweigh the government's interest in promoting effective and efficient public service. The court set forth the framework for analyzing a public employee's First Amendment right of free speech. Meints for leadership positions.īy Order of January 6, 1993, the district court granted defendants' motion for summary judgment. In light of these clashes, the principal and assistant superintendent agreed that they could not recommend either Ms. Cromley and both the principal and the superintendent. There was evidence, as well, of friction between Ms. Until 1987 she had been praised and reappointed each year as Chair of the Reading Department however, her principal's 1986-87 evaluation of her work reported personnel problems in the department and concerns over her effectiveness in the department. ![]() Cromley's later applications to serve as Chapter I Coordinator, Associate English Department Chair, and English Department Chair were denied. Cromley that the Reading Department was being merged with the English Department and would be chaired by a teacher from the English Department. On March 27, 1987, school officials notified Ms. Meints, in turn, sent an angry rebuttal to the plaintiff, principal, and union representative. Cromley, as Reading Department Chair, gave Meints a harsh written evaluation, in which she noted the students' allegations.
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