Lane v. Franks

Lane v. Franks
Argued April 29, 2014
Decided June 19, 2014
Full case nameEdward Lane, Petitioner v. Steve Franks
Docket no.13-483
Citations573 U.S. 228 (more)
134 S. Ct. 2369; 189 L. Ed. 2d 312
Case history
PriorLane v. Cent. Ala. Cmty. Coll., 523 F. App'x 709 (11th Cir. 2013); cert. granted, 571 U.S. 1161 (2014).
Holding
Government employee speech that is made during trial is protected citizen speech, and the employee cannot be fired for comments made in that setting
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajoritySotomayor, joined by unanimous
ConcurrenceThomas, joined by Scalia and Alito

Lane v. Franks, 573 U.S. 228 (2014), is a U.S. Supreme Court case involving public employee's freedom of speech rights. Edward Lane sued Steve Franks for unfairly firing him, out of retaliation for sworn testimony Lane gave during a federal fraud case.[1] The Eleventh Circuit originally ruled in favor of Franks, “denying [Lane] first amendment protection to subpoenaed testimony” (Page 6, section I).[1] The case was argued before the Supreme Court on April 28, 2014. The case was decided on June 19, 2014.[2]

The Supreme Court sided with Lane that he was not responsible for something he said during a federal trial. However, the court could not award damages, because Frank's qualified immunity protected him from being sued in his personal capacity. The case is an important vote of confidence from the Supreme Court about governmental employees not being held responsible for speech that is made as a public citizen on a matter of public concern. It is in line with the Pickering v. Board of Education ruling of 1968 (Opinion para. 1).[3]

  1. ^ a b Goldstein, Thomas (October 18, 2012). "Petition for Writ of Certiorari" (PDF). amazonnews.com. Retrieved March 28, 2017.
  2. ^ "Lane v. Franks". Oyez. Chicago-Kent College of Law. Retrieved March 29, 2017.
  3. ^ Lane v. Franks, 573 U.S. 228 (2014).