Supreme Court of the United States

Edward R. Lane, Petitioner v. Steve Franks

June 19, 2014573 U.S. 228

Summary

The Court held that Edward Lane's truthful sworn testimony, given under subpoena and outside the scope of his ordinary job duties, is protected speech as a citizen on a matter of public concern, but affirmed qualified immunity for Steve Franks in his individual capacity and reversed the Eleventh Circuit’s ruling on official‑capacity claims against Susan Burrow, remanding for further proceedings.

Holding

  • Whether sworn testimony by a public employee, given under subpoena and outside the scope of his ordinary duties, is protected speech as a citizen on a matter of public concern under the First Amendment.. Yes. Such testimony is speech as a citizen and is entitled to First Amendment protection.
  • Whether Steve Franks is entitled to qualified immunity for the individual‑capacity claims.. Yes. Franks is protected by qualified immunity because the right was not clearly established at the time he acted.
  • Whether the Eleventh Circuit’s judgment on the official‑capacity claims against Susan Burrow should be reversed and remanded.. The Eleventh Circuit’s judgment is reversed and the case remanded for further proceedings on the official‑capacity claims.

Docket 13-483

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