ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

funds. Bradshaw would later issue two more letters in the same vein citing the board’s problems
and extolling the board to exonerate her name in regard to the inaccurate charge about the
misusage of funds.
In March 1997, the board offered Bradshaw a $25,000 contract buyout. Bradshaw
declined the buyout and was promptly reassigned as the Alternative School Principal. Following
the reassignment, Bradshaw filed a formal grievance based on the reassignment. Bradshaw
remained in the position until June 17, 1998, when she resigned. Bradshaw filed under § 1983
purporting that her reassignment was retaliation against her right to free speech in criticizing the
board and her discussion of public concerns regarding the management of the school activity
funds by the district. The district court denied the defendant’s motion for summary judgment and
adopted the report. This appeal followed.
Issues: (1) Was the speech that Bradshaw identified of a public concern?
Holding: The court held that none of the speech identified by Bradshaw presented
anything more than personal interest.
Reasoning: The court reasoned that the supposed public concerns about the
mismanagement of the activity fund aired by Bradshaw in her letters were little more than
additional information. Moreover, that information was used by Bradshaw to personally request
that her own name and reputation be cleared of any wrongdoing. The correspondence from
Bradshaw to Pittsburg ISD was little more than letters of a disgruntled employee and her
employer. The form of the letters was official in her title as principal and her employment of
school letterhead detracted from Bradshaw’s supposed “public” concerns. Finally, the context in
which these letters were written was the timeframe immediately following her reassignment,
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