James M. Scott, Jr. v. Robert C. Flowers

910 F.2d 201, 108 A.L.R. Fed. 91, 1990 U.S. App. LEXIS 14495, 1990 WL 119339
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 20, 1990
Docket89-2491
StatusPublished
Cited by115 cases

This text of 910 F.2d 201 (James M. Scott, Jr. v. Robert C. Flowers) 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
James M. Scott, Jr. v. Robert C. Flowers, 910 F.2d 201, 108 A.L.R. Fed. 91, 1990 U.S. App. LEXIS 14495, 1990 WL 119339 (5th Cir. 1990).

Opinions

JERRY E. SMITH, Circuit Judge:

Today we are asked to decide whether an elected judge may constitutionally be reprimanded for making truthful public statements critical of the administration of the county judicial system of which he is a part. Concluding (1) that such statements address matters of legitimate public concern and (2) that the state’s interest in promoting the efficiency and impartiality of its courts does not, under the circumstances of this case, outweigh the plaintiff’s countervailing first amendment right to air his views, we reverse the judgment of the district court and remand for further proceedings.

I.

A.

In 1982, plaintiff James M. Scott, Jr., was elected to a four-year term as justice of the peace in Fort Bend County, Texas. As in many states, justices of the peace in Texas occupy the lowest rung of the judicial hierarchy. Their courts have jurisdiction to hear only petty criminal prosecutions (such as traffic violations), actions for forcible entry and detainer, and other civil cases in which the amount in controversy does not exceed $2,500. See Tex. Const. Art. V, § 19; Tex.Gov’t Code Ann. § 27.031. In most Texas counties, Fort Bend among them, justice courts are not courts of record, and parties appealing from their judgments are entitled to a trial de novo in a higher court.

Soon after taking office, Scott became concerned about what he perceived to be an injustice in the administration of the county court system. Apparently, the great majority of defendants who appealed their traffic offense convictions from justice or municipal courts to the Fort Bend County [204]*204Court-at-law during Scott’s term in office succeeded in having the charges against them dismissed or the fines sharply reduced.1 This practice, Scott believed, unfairly allowed those “in the know” to violate the traffic laws repeatedly and with impunity while penalizing less sophisticated individuals who committed the same offenses.

In September 1983, Scott took his concerns to the local government and the citizenry by writing an “open letter” to county officials. In the letter, Scott attacked the district attorney’s office and the county court-at-law for dismissing so many traffic ticket appeals and called upon the county officials to offer suggestions to remedy the problem. If the county refused to change this practice, Scott concluded, the public at least should be made aware of it, and the court-at-law “would be really busy then.”2

The letter was circulated to the local press and prompted several newspaper articles. It also attracted the attention of Thomas Culver, one of the judges of the court-at-law, who wrote Scott an angry letter criticizing him for not raising his concerns privately. Eventually, both the newspaper articles and Culver’s • letter found their way into the files of the Texas Commission on Judicial Conduct (the “Commission”).3

In November 1983, the Commission’s executive director, defendant Robert C. Flowers, advised Scott by letter that he had been the subject of several complaints received by the Commission.4 Scott responded to the complaints both in writing and in person, having been invited by Flowers to appear informally before the Commission.

On March 19, 1984, the Commission issued a formal public reprimand of Scott. After first acknowledging that Scott’s intentions were good and his personal integrity was not at issue, the Commission then chided him for being “insensitive” in certain “written and oral communications” addressed both to the litigants in his courtroom and to the public at large. Such “insensitivity,” the Commission stated, was inconsistent with the proper performance of Scott’s duties as justice of the peace and served only to “cast public discredit upon the judiciary.” The Commission concluded the reprimand with a warning, advising Scott to be “more restrained and temperate in written and oral communications in the future.”

Although the Commission failed to cite any examples of Scott’s alleged insensitivi[205]*205ty to litigants,5 it was quite specific in identifying the public comments it found to be objectionable. The Commission criticized Scott both for his statement in the open letter that the county court-at-law “would be really busy” if the public realized that an appeal of a traffic ticket was tantamount to a dismissal and for his comment to a reporter, in connection with the letter, that “the county court system is not interested in justice.”6

B.

In March 1986, Scott filed this 42 U.S.C. § 1983 action against the members of the Commission, both individually and in their official capacities. He alleged that his open letter, and his comments to reporters in connection with it, were protected speech for which he could not constitutionally be subject to discipline. Scott’s complaint sought a declaratory judgment that portions of the reprimand violated his first amendment rights, an injunction ordering the Commission to expunge those offending portions from his record, and attorneys’ fees pursuant to 42 U.S.C. § 1988, but did not request any monetary damages.

After the parties had completed discovery, both sides moved for summary [206]*206judgment. In support of its motion, the Commission7 introduced identical affidavits from nine (a majority) of its members, each stating that while Scott’s open letter had been a “substantial factor” in the affiant’s decision to vote in favor of reprimand, it had been “by no means the controlling factor.” The affidavits were uncontrovert-ed, and, unlike the reprimand itself, listed specific examples of Scott’s “insensitivity” to the litigants in his courtroom and explained that those incidents, along with the open letter, had prompted the reprimand.

The Commission argued that the summary judgment record established that Scott would have been reprimanded even if he had not written the open letter or shared his views with reporters and therefore that, under the analysis set forth in Mt. Healthy City School Dist. Bd. of Educ. v. Doyle, 429 U.S. 274, 97 S.Ct. 568, 50 L.Ed.2d 471 (1977), he was entitled to no relief even if his public comments were in fact protected speech. Scott responded that Mt. Healthy was inapplicable because he, unlike the plaintiff in that case, did not seek to be placed in a better position because of his constitutionally protected conduct. Moreover, he contended that the summary judgment record amply demonstrated that his statements addressed matters of public concern and that his right to make them was not outweighed by the Commission’s asserted interest in maintaining the integrity of the state’s judicial system.

C.

The district court granted summary judgment in favor of the Commission. Without citing Mt. Healthy, but apparently relying upon it, the court concluded that Scott would have been reprimanded even if he had not written the open letter and therefore that he was entitled to no relief.

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Bluebook (online)
910 F.2d 201, 108 A.L.R. Fed. 91, 1990 U.S. App. LEXIS 14495, 1990 WL 119339, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-m-scott-jr-v-robert-c-flowers-ca5-1990.