Coollick v. Hughes
On a motion for summary judgment, a court can dismiss a claim based on qualified immunity, if an official establishes no rational jury could conclude: 1.) that the official violated a statutory or constitutional right; and 2.) that the right was clearly established at the time of the challenged conduct. In 2001, Linda Coollick was hired as a guidance coordinator at Vinal Technical High School. Coollick obtained tenure in 2003. Coollick experienced difficulty with the principal and consulted Abigail Hughes, the superintendent of the technical high school system. Coollick transferred to work at Prince Technical High School as a guidance counselor, which was a demotion. In 2007, Hughes transferred Coollick to Cheney Technical High School. Allegedly, Hughes assured Coollick that she could return to Prince the following year, without any change in pay. In November 2007, Hughes informed Coollick that her job at Cheney would be eliminated in May. Coollick sued Abigail Hughes, because she believed that Hughes broke her promise that Coollick could return to Prince. Coollick's complaint alleged that as a tenured worker she was entitled to a pre-termination hearing, before discharge. Hughes objected that Coollick, who had been awarded tenure as a coordinator, lost tenure when she transferred to Prince and worked as a counselor. Coollick continued to prosecute her suit against Hughes in District Court, even after arbitrators reinstated her with back pay and benefits. Hughes moved for summary judgment and argued that she was entitled to qualified immunity. The District Court found that Coollick possessed a clearly established right to continued work, and that it was objectively unreasonable for Hughes to discharge Coollick. Hughes appealed to the 2nd Circuit, which reviewed de novo. Hughes' actions were not objectively unreasonable in light of the law that existed at the time. Hughes sent Coollick reasonably clear notice, which permitted Coollick to file a grievance. Coollick received adequate post-deprivation remedies, because she was reinstated when she filed a grievance. Hughes did not violate Coollick's constitutional rights during the discharge and was entitled to qualified immunity. The 2nd Circuit reversed and remanded, with directions to grant judgment to Hughes.