Houston Community College System v. Wilson

Summary

The Court held that an elected board member does not have an actionable First Amendment retaliation claim based solely on a public, verbal censure issued by fellow members of the same elected body. Historical practice and contemporary retaliation doctrine showed that the censure was not a materially adverse action because it did not prevent Wilson from performing his duties, deny him an office privilege, or materially deter his speech. The Court also declined to review challenges to nonverbal penalties because Wilson had not filed a cross-petition. No separate opinions were issued.