RESPONDENT:City of Shelby, Mississippi
LOCATION: United States District Court for the Northern District of Mississippi
DOCKET NO.: 13-1318
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Fifth Circuit
CITATION: 574 US (2014)
GRANTED: Nov 10, 2014
DECIDED: Nov 10, 2014
Facts of the case
Tracey L. Johnson and David James, Jr., were police officers for the city of Shelby, Mississippi. In September 2009, the city’s board of aldermen, which has sole authority over the city’s employment decisions, fired Johnson and James supposedly for violations of police procedure and residents’ rights. Johnson and James sued the city in district court and argued that they were fired because they refused to ignore the criminal activities of Harold Billings, one of the city’s aldermen. Therefore, the city’s decision to fire Johnson and James violated their Fourteenth Amendment Due Process rights and maliciously interfered with their employment in violation of state law. The city moved for summary judgment based on the fact that Johnson and James failed to include a civil action for deprivation of rights under Section 1983 in their complaint. The district court granted the motion for summary judgment and denied James and Johnson’s subsequent motion to amend their complaint. The U.S. Court of Appeals for the Fifth Circuit affirmed the lower court’s decisions.
Did the trial court correctly grant the motion for summary judgment?