Bointy v. State of Oklahoma

CourtDistrict Court, W.D. Oklahoma
DecidedJune 23, 2025
Docket5:23-cv-01002
StatusUnknown

This text of Bointy v. State of Oklahoma (Bointy v. State of Oklahoma) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bointy v. State of Oklahoma, (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

JANESSA BOINTY, ) ) Plaintiff, ) ) v. ) Case No. CIV-23-1002-SLP ) STATE OF OKLAHOMA, ex rel, ) OKLAHOMA STATE DEPARTMENT ) OF EDUCATION, and RYAN WALTERS, ) in his Official Capacity as Superintendent ) of Public Instruction, and in his Individual ) Capacity, ) ) Defendants. )

O R D E R Before the Court is the Motion for Summary Judgment, with Brief in Support, of Defendant Ryan Walters in his Individual Capacity [Doc. No. 78]. Plaintiff has filed a Response in Opposition [Doc. No. 110] and Defendant has filed a Reply [Doc. No. 113].1 The matter is fully briefed and ready for determination. For the reasons that follow, Defendant Walters’ Motion is GRANTED. I. Background Plaintiff, Janessa Bointy (Ms. Bointy), is a former employee of the Oklahoma State Department of Education (OSDE). On March 9, 2023, Ms. Bointy’s employment was terminated. Ms. Bointy alleges that she was fired by the OSDE in retaliation for exercising

1 Citations to the parties’ briefing submissions reference the Court’s ECF pagination. her First Amendment rights a few days prior, on March 6, 2023, when she spoke at a school board meeting for Edmond Public Schools. Defendant Ryan Walters (Defendant Walters) is the Superintendent of Public

Instruction for the State of Oklahoma (Superintendent). He held that position at the time of Ms. Bointy’s termination. In this Order, all references to Defendant Walters are made as to claims against him in his individual capacity. Ms. Bointy originated this action in the District Court of Oklahoma County, State of Oklahoma. See Pet. [Doc. No. 1-2]. Defendants then removed the action to federal

court on the basis of federal question subject matter jurisdiction. See Notice of Removal [Doc. No. 1]. In the course of the parties’ summary judgment briefing, Ms. Bointy clarifies that the sole claim she brings against Defendant Walters is in his individual capacity pursuant to 42 U.S.C. § 1983 for an alleged violation of her free speech rights under the First Amendment to the United States Constitution. See Pl’s. Resp. in Opp. To Official

Defs.’ Mot. for Summ. J. [Doc. No. 107] at 6-7. Defendant Walters moves for summary judgment raising the defense of qualified immunity. He relies on both prongs of the qualified immunity analysis and asserts that: (1) Ms. Bointy cannot establish that Defendant Walters violated her constitutional rights; and (2) Ms. Bointy cannot show that his conduct violated clearly established federal law.

Central to the parties’ dispute is whether Defendant Walters can be held liable for the decision to terminate Ms. Bointy. Although Ms. Bointy agrees that Defendant Walters did not participate in any manner in her termination, Ms. Bointy claims that, as Superintendent, Defendant Walters is responsible for the policies that were used as the basis to terminate her employment. The Court finds Ms. Bointy has failed to establish any basis upon which to hold Defendant Walters responsible for the termination of her employment and, accordingly, that Defendant Walters is entitled to qualified immunity.

II. The Law of the Case Doctrine Does not Preclude Defendant Walters from Asserting Qualified Immunity at the Summary Judgment Stage

Before proceeding to the qualified immunity analysis, the Court addresses Ms. Bointy’s preliminary argument that the law of the case doctrine precludes Defendant Walters from raising qualified immunity at the summary judgment stage of proceedings. See Pl.’s Resp. at 18-19. This case was previously assigned to a different district judge who addressed qualified immunity in the context of a motion to dismiss filed by Defendant Walters in his individual capacity. The issue as then raised required the Court to determine whether Ms. Bointy’s speech was protected by the First Amendment and specifically, whether her speech was made pursuant to her official duties as an OSDE employee. The Court addressed both prongs of the qualified immunity analysis and found dismissal on grounds of qualified immunity was not proper. See Order [Doc. No. 19]. The issue currently pending before the Court is not whether Ms. Bointy’s speech

was protected by the First Amendment, but whether Defendant Walters is subject to supervisory liability for any alleged violation of Ms. Bointy’s First Amendment rights.2 Because this issue is distinct from the issue previously addressed by the Court, Ms.

2 Although the question of supervisory liability is a component of liability under § 1983 it is also “incorporate[d] into [the court’s] qualified immunity analysis, where [the court] ask[s] whether a clearly established constitutional right has been violated.” Pahls v. Thomas, 718 F.3d 1210, 1227 (10th Cir. 2013). Bointy’s reliance on the law of the case doctrine is misplaced. More fundamentally, the Court’s prior ruling was an interlocutory ruling, to which the law of the case doctrine does not apply. See, e.g., Rimbert v. Eli Lilly & Co., 647 F.3d 1247, 1252 (10th Cir. 2011) (In

the Tenth Circuit, “law of the case doctrine has no bearing on the revisiting of interlocutory orders, even when a case has been reassigned from one judge to another.”); see also In re Syngenta AG MIR 162 Corn Litig., 61 F.4th 1126, 1211 (10th Cir. 2023) (“[T]he law of the case doctrine is fundamentally permissive[.]”).3 Accordingly, the Court addresses the issue of qualified immunity as now raised by Defendant Walters.

III. Defendant Walters is Entitled to Qualified Immunity as Ms. Bointy Has Not Shown His Supervisory Liability

A. Governing Standard The doctrine of qualified immunity “protects public employees from both liability and from the burdens of litigation arising from their exercise of discretion.” Cummings v. Dean, 913 F.3d 1227, 1239 (10th Cir. 2019) (internal quotation marks and citation omitted). “When properly applied, it protects all but the plainly incompetent or those who knowingly violate the law.” Ashcroft v. al-Kidd, 563 U.S. 731, 743 (2011) (internal quotation marks and citation omitted). “When a defendant raises a qualified immunity defense on summary judgment, the onus is on the plaintiff to demonstrate (1) that the

3 The law of the case doctrine does not bar review of issues of qualified immunity even where such issues are immediately appealable. See Stewart v. Beach, 701 F.3d 1322, 1329 (10th Cir. 2012) (finding “no force” to appellant’s argument that previously assigned district judge’s denial of qualified immunity was binding on subsequently assigned judge as law of the case because it was a final appealable order from which the appellee did not immediately appeal). official violated a statutory or constitutional right, and (2) that the right was “clearly established” at the time of the challenged conduct.” Johnson v. City of Cheyenne, 99 F.4th 1206, 1217 (10th Cir. 2024) (emphasis in original; internal quotations marks and citations

omitted). The court accepts the plaintiff’s version of the facts, but those facts must find support in the record. Id. B. Undisputed Material Facts4 Ms. Bointy was formerly employed by the OSDE as a School Counselor Specialist for Project AWARE East. She was employed in that capacity from approximately

December 28, 2020 until March 9, 2023.

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