Miami-Dade School Board Wins First Amendment Ruling
“Whether they spoke as private citizens or public employees and about matters of public concern makes all the difference," 11th Circuit Judge Stanley Marcus said.
August 14, 2018 at 03:02 PM
3 minute read
The U.S. Court of Appeals for the Eleventh Circuit has ruled in favor of the Miami-Dade County School Board in a suit brought by two administrators who claimed their First Amendment rights were violated.
Alberto Fernandez, principal, and Henny Cristobol, assistant principal, claimed they were demoted and disciplined for their efforts to turn the historic Neva King Campbell Educational Center into a charter school. After originally opening in 1913 as an elementary school, the center was renovated and reopened in the 1980s to serve students with intellectual disabilities.
“Determined to improve the school's instructional quality, Fernandez and Cristobol resolved to convert Neva King into a charter school,” Judge Stanley Marcus wrote for a panel of three, including Circuit Judge Charles Wilson and District Judge Marcia Howard of the Middle District of Florida, sitting by designation. “They directed staff members to research charter conversion. They held a faculty meeting, where they attempted to mobilize the faculty's support for their initiative. Moreover, with Cristobol's assistance, Fernandez urged Neva King's Educational Excellence School Advisory Council ('the School Advisory Council') to pursue charter conversion.”
After the council agreed to hold a vote, Fernandez and Cristobol began work on the balloting process.
But the charter movement did not last, according to the decision, as the Miami-Dade County School Board launched an investigation, leading to disciplinary measures. The plaintiffs claimed they were reassigned to “tedious tasks for which they were overqualified,” and lodged their First Amendment suit in federal court, seeking restoration of their previous jobs.
District Judge Darrin Gayles, granting the school board's summary judgment motion, “concluded that their speech was not constitutionally protected because it was uttered pursuant to and as part of their 'official duties' as public employees, and, therefore, granted summary judgment to the School Board,” Marcus wrote.
The 23-page opinion issued Friday in the appeal answered one question.
“The only issue we address today is whether the district court properly concluded that the Administrators' speech was not protected by the First Amendment,” Marcus said. “We hold that it did.”
The decision turned on the fact that the administrators were speaking as public employees and in the scope of their official duties. Speaking as private citizens on matters of public interest is a different matter, Marcus said.
“Whether they spoke as private citizens or public employees and about matters of public concern makes all the difference,” Marcus said. “Sometimes, answering these questions is difficult, particularly as we remember that 'citizens do not surrender their First Amendment rights by accepting public employment.' Lane v. Franks, 134 S. Ct. 2369, 2374 (2014). This is not one of those cases.”
“The long and short of it is that the principal and assistant principal of Neva King Cooper Educational Center spearheaded this charter school conversion pursuant to their official duties. They may not sue the School Board under the First Amendment,” Marcus concluded. “We affirm.”
The school board was represented by in-house counsel Luis Garcia.
Fernandez and Cristobol were represented by: Thomas Elfers of Miami and Craig Freger of Pembroke Pines.
The attorneys did not return calls for comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllVedder Price Shareholder Javier Lopez Appointed to Miami Planning, Zoning & Appeals Board
2 minute readCrypto Entrepreneur Claims Justice Department’s Software Crackdown Violates US Constitution
4 minute readTrending Stories
- 1South Florida Attorney Charged With Aggravated Battery After Incident in Prime Rib Line
- 2'A Death Sentence for TikTok'?: Litigators and Experts Weigh Impact of Potential Ban on Creators and Data Privacy
- 3Bribery Case Against Former Lt. Gov. Brian Benjamin Is Dropped
- 4‘Extremely Disturbing’: AI Firms Face Class Action by ‘Taskers’ Exposed to Traumatic Content
- 5State Appeals Court Revives BraunHagey Lawsuit Alleging $4.2M Unlawful Wire to China
Who Got The Work
J. Brugh Lower of Gibbons has entered an appearance for industrial equipment supplier Devco Corporation in a pending trademark infringement lawsuit. The suit, accusing the defendant of selling knock-off Graco products, was filed Dec. 18 in New Jersey District Court by Rivkin Radler on behalf of Graco Inc. and Graco Minnesota. The case, assigned to U.S. District Judge Zahid N. Quraishi, is 3:24-cv-11294, Graco Inc. et al v. Devco Corporation.
Who Got The Work
Rebecca Maller-Stein and Kent A. Yalowitz of Arnold & Porter Kaye Scholer have entered their appearances for Hanaco Venture Capital and its executives, Lior Prosor and David Frankel, in a pending securities lawsuit. The action, filed on Dec. 24 in New York Southern District Court by Zell, Aron & Co. on behalf of Goldeneye Advisors, accuses the defendants of negligently and fraudulently managing the plaintiff's $1 million investment. The case, assigned to U.S. District Judge Vernon S. Broderick, is 1:24-cv-09918, Goldeneye Advisors, LLC v. Hanaco Venture Capital, Ltd. et al.
Who Got The Work
Attorneys from A&O Shearman has stepped in as defense counsel for Toronto-Dominion Bank and other defendants in a pending securities class action. The suit, filed Dec. 11 in New York Southern District Court by Bleichmar Fonti & Auld, accuses the defendants of concealing the bank's 'pervasive' deficiencies in regards to its compliance with the Bank Secrecy Act and the quality of its anti-money laundering controls. The case, assigned to U.S. District Judge Arun Subramanian, is 1:24-cv-09445, Gonzalez v. The Toronto-Dominion Bank et al.
Who Got The Work
Crown Castle International, a Pennsylvania company providing shared communications infrastructure, has turned to Luke D. Wolf of Gordon Rees Scully Mansukhani to fend off a pending breach-of-contract lawsuit. The court action, filed Nov. 25 in Michigan Eastern District Court by Hooper Hathaway PC on behalf of The Town Residences LLC, accuses Crown Castle of failing to transfer approximately $30,000 in utility payments from T-Mobile in breach of a roof-top lease and assignment agreement. The case, assigned to U.S. District Judge Susan K. Declercq, is 2:24-cv-13131, The Town Residences LLC v. T-Mobile US, Inc. et al.
Who Got The Work
Wilfred P. Coronato and Daniel M. Schwartz of McCarter & English have stepped in as defense counsel to Electrolux Home Products Inc. in a pending product liability lawsuit. The court action, filed Nov. 26 in New York Eastern District Court by Poulos Lopiccolo PC and Nagel Rice LLP on behalf of David Stern, alleges that the defendant's refrigerators’ drawers and shelving repeatedly break and fall apart within months after purchase. The case, assigned to U.S. District Judge Joan M. Azrack, is 2:24-cv-08204, Stern v. Electrolux Home Products, Inc.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250