Earnest v. Board of Education of Jasper County Community Unit School District No. 1

371 F. Supp. 3d 459
CourtDistrict Court, S.D. Illinois
DecidedMarch 4, 2019
DocketCase No. 17-cv-1380-JPG-GCS
StatusPublished

This text of 371 F. Supp. 3d 459 (Earnest v. Board of Education of Jasper County Community Unit School District No. 1) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Earnest v. Board of Education of Jasper County Community Unit School District No. 1, 371 F. Supp. 3d 459 (S.D. Ill. 2019).

Opinion

J. PHIL GILBERT, DISTRICT JUDGE

This matter comes before the Court on the defendants' motion for summary judgment (Doc. 41). Plaintiff Jerry L. Earnest has responded to the motion (Doc. 49), and the defendants have replied to that response (Doc. 50). The Court also considers Earnest's motion for sanctions (Doc. 45), to which the defendants have responded (Doc. 51).

Earnest, an elected member of the Board of Education of Jasper County Community Unit School District No. 1 ("Board"), filed this lawsuit claiming that the defendants-the Board, School Superintendent Andrew D. Johnson, and Board members John Fulton (president), Gordon Millsap, Holly Farley, Mandy Rieman, Melissa Stanley, and Rob Street-deprived him of a liberty interest without procedural due process in violation of the Fourteenth Amendment Due Process Clause. He claims they did this by refusing to provide him with confidential information that was provided to the rest of the Board, by seeking his discharge, and by censuring him. He claims this effectively deprived him of his elected position on the Board and damaged his reputation. Whether the defendants deprived Earnest of a protected liberty interest and, if so, whether he was accorded due process are the main questions before the Court in the pending summary judgment motion.

I. Summary Judgment Standard

Summary judgment must be granted "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a) ; see Celotex Corp. v. Catrett , 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986) ; Spath v. Hayes Wheels Int'l-Ind., Inc. , 211 F.3d 392, 396 (7th Cir. 2000). The court must construe the evidence in the light most favorable to the nonmoving party and draw all reasonable inferences in favor of that party. See Anderson v. Liberty Lobby, Inc. , 477 U.S. 242, 255, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986) ; Chelios v. Heavener , 520 F.3d 678, 685 (7th Cir. 2008) ; Spath , 211 F.3d at 396.

The initial summary judgment burden of production is on the moving party to show the Court that there is no reason to have a trial. Celotex , 477 U.S. at 323, 106 S.Ct. 2548 ; Modrowski v. Pigatto , 712 F.3d 1166, 1168 (7th Cir. 2013). Where the non-moving party carries the burden of proof at trial, the moving party may satisfy its burden of production in one of two ways. It may present evidence that affirmatively negates an essential element of the non-moving party's case, see Fed. R. Civ. P. 56(c)(1)(A), or it may point to an absence of evidence to support an essential element of the non-moving party's case without actually submitting any evidence, see Fed. R. Civ. P. 56(c)(1)(B). Celotex , 477 U.S. at 322-25, 106 S.Ct. 2548 ; Modrowski , 712 F.3d at 1169. Where the moving party fails to meet its strict burden, a court cannot enter summary judgment for the moving party even if the opposing party fails to present relevant evidence in response to *463the motion. Cooper v. Lane , 969 F.2d 368, 371 (7th Cir. 1992).

In responding to a summary judgment motion, the nonmoving party may not simply rest upon the allegations contained in the pleadings but must present specific facts to show that a genuine issue of material fact exists. Celotex , 477 U.S. at 322-26, 106 S.Ct. 2548 ; Anderson , 477 U.S. at 256-57, 106 S.Ct. 2505 ; Modrowski , 712 F.3d at 1168. A genuine issue of material fact is not demonstrated by the mere existence of "some alleged factual dispute between the parties," Anderson , 477 U.S. at 247, 106 S.Ct. 2505, or by "some metaphysical doubt as to the material facts," Matsushita Elec. Indus. Co. v. Zenith Radio Corp. , 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). Rather, a genuine issue of material fact exists only if "a fair-minded [factfinder] could return a verdict for the [nonmoving party] on the evidence presented." Anderson , 477 U.S. at 252, 106 S.Ct. 2505.

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Bluebook (online)
371 F. Supp. 3d 459, Counsel Stack Legal Research, https://law.counselstack.com/opinion/earnest-v-board-of-education-of-jasper-county-community-unit-school-ilsd-2019.