City Of St Louis v. Praprotnik

485 U.S. 112 (1988)

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Nature of the Case

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Facts

P is an architect who began working for D. P consistently received favorable evaluations of his job performance, uncommonly quick promotions, and significant increases in salary. By 1980, he was serving in a management-level city planning position. P had to obtain advance approval before taking on private clients. P and other employees objected to the requirement. P was disciplined for taking on other work without approval. The Commission's decision was not well received by P's supervisors. P’s boss believed P had lied to the Commission. P's next two annual job performance evaluations were markedly less favorable than those in previous years. His boss mentioned his displeasure with P's appeal to the Civil Service Commission. P appealed both evaluations to the Department of Personnel. In each case, the Department ordered partial relief which was upheld by the city's Director of Personnel or the Civil Service Commission. In April 1981, a new mayor came into office. Budget cuts and a number of layoffs and transfers significantly reduced the size of P’s department and the planning section in which P worked. P was retained. A second round of layoffs and transfers occurred. D's Heritage and Urban Design Division (Heritage) was seeking approval to hire someone who was qualified in architecture and urban planning. It was agreed to transfer certain functions from P's group to Heritage. Heritage would then employ a relatively high-level 'city planning manager.' P was transferred to Heritage to fill the position. P objected and appealed to the Civil Service Commission. The Commission declined to hear the appeal because P had not suffered a reduction in his pay or grade. P filed suit in federal district court, alleging that the transfer was unconstitutional. D was named as a defendant along with Kindleberger, Hamsher, Jackson (whom P deleted from the list before trial), and Deborah Patterson. P became embroiled in a series of disputes with Jackson and Jackson's successor, Robert Killen. P was dissatisfied with the work he was assigned, which consisted of unchallenging clerical functions far below the level of responsibilities that he had previously enjoyed. An adverse personnel decision was taken against P, and he obtained partial relief after appealing that decision. P was laid off from Heritage because P's supervisors had concluded that they could create two lower-level positions with the funds that were being used to pay P's salary. P amended the complaint to include a challenge to the layoff. P appealed to the Civil Service Commission, but proceedings in that forum were postponed because of the pending lawsuit and have never been completed. P claimed his First Amendment rights had been violated through retaliatory actions taken in response to the appeal of his 1980 suspension; and (2) P's layoff from Heritage was carried out for pretextual reasons in violation of due process. P claimed his First Amendment rights had been violated through retaliatory actions taken in response to the appeal of his 1980 suspension; and (2) P's layoff from Heritage was carried out for pretextual reasons in violation of due process. The jury exonerated the three individual defendants but found D liable under both theories. D appealed. The Court of Appeals affirmed the verdict holding D liable for violating P's First Amendment rights. The Court concluded that D could be held liable for adverse personnel decisions taken by P's supervisors. In response to P's contention that personnel policies are actually set by the Civil Service Commission, the Court of Appeals concluded that the scope of review before that body was too 'highly circumscribed' to allow it fairly to be said that the Commission, rather than the officials who initiated the actions leading to respondent's injury, was the 'final authority' responsible for setting D's policy. It held that P's transfer to Heritage had been 'orchestrated' by Hamsher, that the transfer had amounted to a 'constructive discharge,' and that the injury had reached fruition when P was eventually laid off by Nash and Killen. The dissent concluded that P had submitted no evidence proving that the mayor and aldermen, or the Commission, had established a policy of retaliating against employees for appealing from adverse personnel decisions. D appealed.