Sunday, November 24, 2013

Schultea v. Wood case brief

Schultea v. Wood case brief summary
47 F.3d 1427 (5th Cir. 1995) (en banc)


CASE SYNOPSIS
Defendant public officials appealed a judgment of the United States District Court for the Southern District of Texas denying their motion to dismiss plaintiff's procedural due process claims and his claim under the U.S. Constitutional Amendment I, in an action which alleged that defendants conspired to demote him after he reported illegal activity to state authorities. Defendants contended the court erred in rejecting their defense of qualified immunity.

CASE FACTS
Plaintiff filed suit against defendant public officials alleging that defendants conspired to demote him after he reported possible illegal activity to state authorities. Defendants filed a motion to dismiss plaintiff's procedural due process claims and his claim under the First Amendment, which the trial court denied.

DISCUSSION

  • On review, defendants contended the trial court erred in rejecting their defense of qualified immunity. 
  • The appeals court affirmed the trial court's denial of the motion to dismiss plaintiff's First Amendment claim, but reversed its denial of the motion to dismiss the claims of denied procedural due process and remanded to allow plaintiff to amend the complaint. 
  • The court reasoned that in suits filed under 42 U.S.C.S. § 1983 against public officials in their private capacity, a claim had to be stated with particularity. 
  • The court ruled that pursuant to Fed. R. Civ. P. 7, when a public official pleaded the affirmative defense of qualified immunity in his answer, the district court could require the plaintiff to reply to that defense in detail. 
  • The court noted that the reply had to be tailored to the assertion of qualified immunity and fairly engage its allegations.

CONCLUSION
The appeals court affirmed the trial court's denial of the motion to dismiss plaintiff's First Amendment claim, but reversed its denial of the motion to dismiss the claims of denied procedural due process and remanded to allow plaintiff to amend the complaint. The court ruled that on remand, plaintiff was required to plead his civil rights claim against defendant public officials in their private capacity with particularity.

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