McGreal v. The Village of Orland Park

Federal 7th Circuit Court
Civil Court
First Amendment
Citation
Case Number: 
No. 16-2365
Decision Date: 
March 6, 2017
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in section 1983 action alleging that defendant terminated plaintiff-police officer in retaliation for his exercise of protected speech at community board meeting, during which plaintiff advocated for proposed police budget that would protect salaries of lower-level police officers at expense of their superiors. Plaintiff failed to show that applicable decision-makers were aware of plaintiff’s speech at board meeting prior to terminating plaintiff for job misconduct. Moreover, plaintiff failed to present admissible evidence to dispute defendant’s claim that plaintiff was terminated for: (1) lying under oath during certain formal investigations; (2) committing acts of insubordination; and (3) engaging in reckless conduct while on duty. Fact that plaintiff submitted for consideration his own unsigned affidavit, his own written statement of undisputed evidence and his own spreadsheet containing descriptions of alleged incidents did not require different result.