ADVERSE EMPLOYMENT ACTIONS AND PUBLIC SCHOOL ...

which the action occurred. Moreover, the only § 1983 claim that Corbett made was the wrongful
termination, which conformed to the statute of limitations.
Finally, Corbett’s free speech violation claims faltered because Corbett did not meet the
four requirements to warrant a valid First Amendment claim. First, Corbett failed to show that he
engaged in speech that was of a public concern because he failed to adequately provide
information to the context of the speech. Second, because the court could not determine whether
the speech was warranting of protection, it could not weigh whether Corbett’s right to expression
outweighed Duering and the school district’s right to efficient operation of schools. On this front,
Corbett’s argument failed. Third, Corbett did establish that he was deprived of something due to
his speech (i.e., his job was allegedly deprived for his speech). Fourth, Corbett failed to show
that his speech was directly linked to termination of his job.
Disposition: The defendant’s motion for dismissal of case was granted without prejudice.
Citation: Heutzenroeder v. Mesa County Valley School District 51, 391 Fed. Appx. 688,
(2010 U.S. App.).
Key Facts: Heutzenroeder was employed by the Mesa County Valley School District as a
principal; her contract outlined that Heutzenroeder would receive a fixed salary for the duration
of the contract. Her contract, however, did not entitle her to a specific position such as principal,
only the salary. Heutzenroeder served the district as principal of Redlands Middle School for
three school years (2004-2006) with little to no issues.
Near the beginning of the 2007-2008 school year, a student threatened to kill a Redlands
Middle school teacher through a graffiti message in the school restrooms. The district’s
Executive Director of Middle Schools, Debra Bailey, and Executive Director of Human
Resources, Colleen Martin, did not feel that Heutzenroeder had properly handled the situation;
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