Faculty Rights Coalition v. Shahrokhi

204 F. App'x 416
CourtCourt of Appeals for the Fifth Circuit
DecidedNovember 2, 2006
Docket05-21098
StatusUnpublished
Cited by2 cases

This text of 204 F. App'x 416 (Faculty Rights Coalition v. Shahrokhi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Faculty Rights Coalition v. Shahrokhi, 204 F. App'x 416 (5th Cir. 2006).

Opinion

PER CURIAM: *

Plaintiff De Mino, 1 an adjunct faculty member at the University of Houston Downtown (UHD), appeals the district court’s grant of summary judgment in favor of the defendants, UHD officials, in this 42 U.S.C.1983 action. This case stems from UHD officials’s alleged violation of Plaintiffs First Amendment rights, retaliation, and violation of Plaintiffs Fourteenth Amendment rights to Equal Protection of the law. Plaintiff bases his appeal upon the following alleged errors of the district court: (1) the grant of summary judgment for defendants on plaintiffs First Amendment claims (violation by e-mail restrictions and retaliation); (2) the grant of summary judgment for defendants on plaintiffs Equal Protection claims; (8) the ruling that plaintiff lacked standing to challenge the Texas statutes at issue; and (4) award of costs to defendants.

Background

Plaintiff, in his initial complaint, focused on UHD’s policies regarding adjunct faculty member access to their e-mail accounts. 2 In his first amended complaint, he sued Shakrokhi (Executive Director of Information Technology at UHD), and Woods (Chief Academic Officer of UHD). He also sought leave to add Adolfo Santos *418 (Administrative Assistant Chair for the Department of Social Sciences at UHD). In this complaint, De Mino reiterated his complaints regarding the compensation and treatment of adjuncts, as well as email account access, specifying that adjuncts do not have access to their e-mail accounts during any semester they are not teaching, including the summer. He also reiterated that he was denied access to his e-mail account in retaliation for his attempted use of the system to distribute complaints about the UHD administration. In this first amended complaint, he added the allegation that, in retaliation for the current lawsuit, UHD cut his course load from three to two classes, in an effort to deprive him of benefits, 3 terminate his active status in the Teacher Retirement System, and reduce his pay. He further alleged a denial of equal protection in that adjunct faculty are paid less, given fewer benefits, denied opportunities in university governance, and given fewer supporting resources in comparison to full-time, tenure-track faculty members. Lastly, he challenged the constitutionality of Texas statutes that prohibit the unionization of state employees and the ability of non-citizens to become labor union officials or organizers.

The district court granted defendants’ motions for summary judgment on the First Amendment and Equal Protection claims, and ruled that plaintiff lacked standing to challenge the Texas statutes at issue. Further, they awarded costs to the defendants.

Discussion

I. First Amendment Claims

This court reviews the grant of summary judgment de novo, applying the same standard as the lower court. Gowesky v. Singing River Hospital Systems, 321 F.3d 503, 507 (5th Cir.2003). Appellant urges that UHD violated his First Amendment rights by restricting his e-mail account access in an effort to silence his complaints about the university and further contends that UHD retaliated against him for exercising his rights in bringing this lawsuit.

A First Amendment Violation

Appellant bases his assertions mainly upon three actions by UHD IT officials: (1) disallowing adjuncts access to e-mail accounts during the semesters they do not teach, including the summer; (2) restricting adjuncts’ sending of e-mails; and (3) implementing a spam filter.

The Supreme Court has held that a public school system’s internal mail system does not constitute a state-created public forum. Perry Educ. Ass’n v. Perry Local Educators’ Ass’n, 460 U.S. 37, 103 S.Ct. 948, 955-56, 74 L.Ed.2d 794 (1983). Because of this, “[i]n addition to time, place, and manner regulations, the state may reserve the forum for its intended purposes, communicative or otherwise, as long as the regulation on speech is reasonable and not an effort to suppress expression merely because public officials oppose the speaker’s view.” Id. at 955, citing United States Postal Service v. Greenburgh Civic Ass’n, 453 U.S. 114, 101 S.Ct. 2676, 2684, 69 L.Ed.2d 517 (1981); see also Chiu v. Plano Indep. School Dish, 260 F.3d 330, 356 (5th Cir.2001) (“Identity-based and subject matter distinctions in a nonpublic forum are permissible so long as they are not a covert attempt to suppress a particular viewpoint....”). As such, any limitations imposed must be reasonable in light of the purpose served by the forum. Perry, 103 S.Ct. at 957; Chiu, 260 F.3d at 356.

*419 Defendant Shahrokhi presented competent summary- judgment evidence to show there was no First Amendment violation in this case. 4 The disputed restrictions and the spam filter were uniformly applied system-wide and were not content-based; there is no evidence to suggest that the goal of these policies was to suppress any viewpoint. Further, these UHD polices were reasonable in light of the need to control the quantity of data stored on the system and to filter data coming into the system. Doing away with these policies would “substantially interfere with the activities ... of the school.” Tinker v. Des Moines Independent Community School District, 393 U.S. 503, 513, 89 S.Ct. 733, 21 L.Ed.2d 731 (1969).

B. Retaliation

Appellant argues that his course load was reduced in retaliation for filing this lawsuit. To prove a First Amendment retaliation claim under 42 U.S.C.1983, a plaintiff must show: (1) he suffered an adverse employment action; (2) his speech involved a matter of public concern; (3) his interest in commenting on such matters outweighed the government employer’s interest in promoting efficiency; and (4) his speech motivated the adverse employment action. Alexander v. Eeds, 392 F.3d 138, 142 (5th Cir.2004).

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204 F. App'x 416, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faculty-rights-coalition-v-shahrokhi-ca5-2006.