Smith v. County of Suffolk, No. 13-1230 (2d Cir. 2015)
Annotate this CasePlaintiff filed suit against the county and the police commissioner, alleging that he was retaliated against for exercising his First Amendment right to freedom of speech. Because defendants do not challenge them on appeal, the court did not revisit the district court's conclusions that plaintiff's media communications enjoyed First Amendment protection. The court expressed no opinion as to whether plaintiff would have been able to prevail on the basis of his indirect evidence of retaliatory intent; concluded that plaintiff has proffered sufficient direct evidence of retaliatory intent from which a reasonable jury could find a causal connection between his protected speech and the Department's adverse employment actions and, therefore, plaintiff has established a prima facie case of First Amendment retaliation; concluded that defendants are not entitled to summary judgment based on the Mount Healthy City School District Board of Education v. Doyle defense; and concluded that the record raises several genuine questions of material fact such that an award of summary judgment in defendants' favor is unjust. Accordingly, the court vacated the district court's judgment otherwise and remanded for further proceedings.
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