Swetlik v. Crawford

Dist. Ct. did not err in granting defendants-city officials’ motion for summary judgment in section 1983 action alleging that defendants violated plaintiff-police detective’s First Amendment rights when they voted to file termination charge against plaintiff in retaliation for his public criticism of police chief in plaintiff’s role as union member. Although plaintiff could be deemed to have spoken as private citizen about matter of public concern when he accused police chief of urging him to lie to jail officials and threatened him if he did not, summary judgment in defendants’ favor was still appropriate where record showed that defendants reasonably based their actions on contents of investigation report that recommended plaintiff’s termination due to fact that plaintiff had been untruthful (as reflected in recorded telephone conversation) about certain allegations that plaintiff made against police chief. As such, Ct. found that defendants were justified in bringing termination charges against plaintiff.