Section 3617

Citation: Section 3617
Parent Document: Gonzalez v. Lee County Housing Authority, 161 F.3d 1290 (1998)
Jurisdiction: United States (federal)
Effective Date: 1998-12-02
Original Source: https://www.courtlistener.com/opinion/73387/gonzalez-v-lee-county-housing-authority/ ↗

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instances cannot form the basis of a successful claim under § 1983. See
Hughes v. Bedsole, 48 F.3d 1376, 1386 (4th Cir. 1995) (pretermitting
review of § 1983 free speech claim based on lack of causation evidence).
22
  In Connick, Assistant District Attorney Myers opposed District Attorney
Connick’s decision to transfer her. See 461 U.S. at 140-41, 103 S. Ct.
at 1686. As a result of her discontent, Myers prepared and circulated
to other assistant district attorneys a questionnaire concerning office
transfer policy, office morale, the need for a grievance committee, the
level of confidence in supervisors, and whether employees felt pressured
to work in political campaigns. See id. at 141, 103 S. Ct. at 1687.
Connick then terminated Myers. See id.
      The Connick Court analyzed each of the questions in the
questionnaire separately.    Most of the questions were not “of public
import in evaluating the performance of the District Attorney as an
elected official,” 461 U.S. at 148, 103 S. Ct. at 1690, but simply
“reflect[ed] one employee’s dissatisfaction with a transfer and an
attempt to turn that displeasure into a cause cèlèbre,” id. at 148, 103
S. Ct. at 1691. The Court, however, held that the question concerning
whether assistant district attorneys felt pressured to work in political
campaigns did touch upon a matter of public concern in light of: (1) the
constitutional guarantees protecting employees from having to work for
political candidates not of their own choice; and (2) the “demonstrated
interest in this country that government service should depend upon

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