Texas State Teacher’s Association v. Garland Independent School District

Facts

The Texas State Teacher’s Association (P) is an affiliate of the Garland Education Association. P sued the Garland Independent School District alleging that D’s policies prohibited communications by or with teachers during the school day concerning employee organizations. Ps claimed that this violated their First and Fourteenth Amendment Rights. On a cross-motion for summary judgment, the District Court rejected Ps’ claims in almost all respects. On appeal, the Fifth Circuit affirmed in part, reversed in part and remanded. The 5th Circuit agreed that Ps’ claim that D allow union representatives access to school facilities during school hours was foreclosed in our earlier decisions. The Appeals court then found that the prohibition of teacher speech promoting union activity during school hours was unconstitutional and that the possibility of discipline over such matters had a chilling effect on First Amendment rights. The 5th Circuit also held that the prohibition of teachers' use of internal mail and billboard facilities to discuss employee organizations was unconstitutional. As to these claims Ps were granted their motion for summary judgment. D appealed, and the Supreme Court granted certiorari. The Supreme Court summarily affirmed the judgment of the court of appeals. Ps then filed an application for an award of attorney’s fees under 42 U.S.C. 1988. The District Court found that Ps were not prevailing parties and thus were ineligible for any fee award. The court did recognize that Ps had obtained partial success, but the test was whether P had, in fact, prevailed on the central issue by acquiring the primary relief sought. The central issue was then determined to be allowing union access to teachers and school facilities during school hours. A divided panel of the 5th Circuit affirmed. The Supreme Court granted certiorari. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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