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Beattie v. Madison County School District

School employee's First Amendment retaliation claim fails where school board members did not know of employee's support of a school superintendent candidate, but had personal knowledge of complaints against the employee.

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Appeal from the United States District Court for the Southern District of Mississippi

Joy Beattie, an at-will employee, was fired as a secretary for Madison County Schools, allegedly in retaliation for her support of Michael Kent’s candidacy for school superintendent in opposition to the incumbent, Maria Jones. Beattie sued the school district, the superintendent, the principal, and the school board members for First Amendment retaliation under 42 U.S.C. � 1983 and for violation of Miss. Code Ann. � 23-15-871, which prohibits certain actions by employers regarding employee’s voting rights. Beattie asked for a permanent injunction, reinstatement, punitive damages, and compensatory damages for lost past and future wages, mental anguish, emotional stress, and loss of reputation. The district court dismissed the state law claim without prejudice and granted summary judgment for the defendants on the � 1983 claim on the basis that Beattie had failed to establish a causal connection between her political activity and her discharge, an essential element of her � 1983 claim.*fn1

Beattie appeals, contending that the district court erred in concluding that she failed to prove causation and erred in denying her motion to conduct additional discovery under Fed. R. Civ. P. 56(f). We affirm.

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