In Julie McArdle v. Peoria School District No. 50, the Seventh Circuit upheld a lower court’s dismissal of a terminated school principal’s First Amendment and contract claims against a school district. The principal alleged she was fired for reporting her supervisor’s (who was also the previous principal) suspicious use of school funds.
In upholding the lower court’s dismissal of the case, the Seventh Circuit held that a public employee’s First Amendment rights extend only to speech made as a private citizen and not that made as an employee. In determining whether the principal’s speech in this case was private or public, the Court looked beyond her specific job description and legal obligations and instead considered whether her speech pertained to an area within her responsibilities as principal. The Court found her speech regarding school finances and compliance with district policy was made as an employee and not as private citizen. As such, the speech was not protected by the First Amendment.