Wargo v. Moon

323 F. Supp. 2d 846, 2004 WL 1472014
CourtDistrict Court, N.D. Ohio
DecidedJune 21, 2004
Docket3:04 CV 7036
StatusPublished

This text of 323 F. Supp. 2d 846 (Wargo v. Moon) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wargo v. Moon, 323 F. Supp. 2d 846, 2004 WL 1472014 (N.D. Ohio 2004).

Opinion

ORDER

CARR, District Judge.

This is a First Amendment case brought by Louis Wargo, Jr., against his former employer, the Honorable Paul C. Moon, Judge of the Ottawa County, Ohio, Court of Common Pleas. Plaintiff claims that defendant terminated plaintiffs employment for exercising his right to free speech in violation of the First Amendment and Ohio public policy. This court has jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1367.

Pending is defendant’s motion to dismiss each of plaintiffs claims. For the following reasons, defendant’s motion shall be granted.

BACKGROUND

Plaintiff began working as a probation officer for defendant in 1987, while defendant was a Judge of the Port Clinton, Ohio, Municipal Court. In 1991, after defendant was elected to serve as Judge of the Ottawa County Court of Common Pleas, plaintiff became defendant’s Chief Adult Probation Officer and Chief Bailiff.

In 2002, plaintiffs son announced his candidacy for Ottawa County Juvenile/Probate Judge, running as an independent supported by the Ottawa County Republican Party. Defendant was and remains a member of the Ottawa County Democratic Party.

In May, 2002, plaintiff parked his car, on which were displayed stickers supporting his son’s candidacy, in the Ottawa County Court of Common Pleas parking lot. Defendant allegedly instructed plaintiff to remove the stickers or park in the street.

Plaintiff subsequently sent anonymous letters to local newspapers raising questions about the integrity and ethical behavior of the county government and school systems. Although the letters were never published in any newspaper, they specifically accused defendant of creating a questionable magistrate judge position and setting the magistrate up to be his “stooge.” (Doc. 4, Ex. A, at 3). Plaintiffs letters further accused defendant of unethically collecting both a salary and retirement pay and hiding this information from the public to avoid ballot issues that would negatively impact his candidacy by encouraging write-in opposition. Plaintiff also accused defendant and his staff of improperly using visiting judges and working too few hours.

Though the letters had been sent anonymously, defendant became aware of them. He instructed plaintiff to attend a meeting on August 26, 2002. At the meeting, defendant confronted plaintiff about the contents of the communication and terminated plaintiffs employment.

STANDARD OF REVIEW

The court should grant a motion to dismiss only if it is obvious that no relief can be granted under any set of facts that can be proven consistent with the allegations. Swierkiewicz v. Sorema, N.A., 534 U.S. 506, 514, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002). The court must accept as true all of plaintiffs factual allegations. Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 164, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). Dismissal is appropriate only if it appears beyond doubt that the complain *849 ing party can prove no set of facts in support of the claims that would entitle him or her to relief. Pfennig v. Household Credit Servs., 295 F.3d 522, 525-26 (6th Cir.2002) (citing Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.1998)).

DISCUSSION

A. Plaintiffs First Amendment Claim

To recover under 42 U.S.C. § 1983, plaintiff must first plead and prove that: 1) he was denied a right secured by the Constitution and 2) that deprivation was permitted by one acting under color of state law. Parrott v. Taylor, 451 U.S. 527, 535, 101 S.Ct. 1908, 68 L.Ed.2d 420 (1981). There is no dispute here that defendant is a state actor and that he acted under color of state law when he terminated plaintiffs employment. Defendant alleges, however, that plaintiffs claim does not establish that he was denied one of his constitutional rights.

It is a well settled principle of constitutional law that the State cannot condition public employment on a basis that infringes on an employee’s constitutionally protected rights of freedom of speech. Pickering v. Board of Education, 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968); Branti v. Finkel, 445 U.S. 507, 515-516, 100 S.Ct. 1287, 63 L.Ed.2d 574 (1980). The Supreme Court has established a two-part inquiry, based on the Court’s explanation in Pickering that, to determine whether a public employee’s right to free speech has been violated, the employee’s right to free speech must be balanced against government’s interests. Connick v. Myers, 461 U.S. 138, 103 S.Ct. 1684, 75 L.Ed.2d 708 (1983). First, the court must determine “whether the employee’s speech may be fairly characterized as constituting speech on a matter of public concern.” Dambrot v. Central Michigan Univ., 55 F.3d 1177, 1186 (6th Cir.1995) (citing Connick, 461 U.S. at 146, 103 S.Ct. 1684) (internal quotation omitted). “[I]f the speech is found to touch upon a matter of public concern,” then “the employee’s First Amendment rights have been violated” where “the employee’s free speech interests outweigh the efficiency interests of the government as employer,-” Id. at 1186;' see also Connick, 461 U.S. at 142, 103 S.Ct. 1684 (“Our task ... is to seek ‘a balance between the interests of the [employee], as a citizen, in commenting upon matters of public concern and the interest of the State, as an employer, in promoting the efficiency of the public services it performs through its employees.’ ” (quoting Pickering, 391 U.S. at 568, 88 S.Ct. 1731)).

There are limited exceptions to this rule involving what is generally termed, though not limited to, a “confidential” or “policymaking” employee. See Elrod v. Burns, 427 U.S. 347, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976); Branti, 445 U.S. at 518, 100 S.Ct. 1287 (“the question is whether the hiring authority can demonstrate that party affiliation is an appropriate requirement for the effective performance of the public office involved”). If a “confidential” or “policymaking” employee is “discharged on the basis of speech related to his political or policy views, the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
323 F. Supp. 2d 846, 2004 WL 1472014, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wargo-v-moon-ohnd-2004.