Episode 24: Henderson v. Springfield R-12 School District

Henderson v. Springfield R-12 School District, argued en banc before the U.S. Court of Appeals for the Eighth Circuit on January 15, 2025. Argued by Braden H. Boucek of the Southeastern Legal Foundation (on behalf of Brooke Henderson, et al.) and Tina Fowler (on behalf of the Board of Education of the Springfield R-12 School District, et al.).

Background of the case, from Circuit Judge Colloton’s Eighth Circuit panel opinion:

In 2020, the Springfield R-12 School District required its employees to attend “equity training.” Two employees who attended the training sued the school district and several school officials under 42 U.S.C. § 1983. The plaintiffs alleged that during the training, the defendants compelled them to speak as private citizens on matters of public concern, and engaged in viewpoint discrimination in violation of the First and Fourteenth Amendments. The district court granted summary judgment for the school district on the ground that the plaintiffs did not suffer an injury in fact and thus lacked standing to sue. The court also found that the lawsuit was frivolous and awarded attorney’s fees to the school district. The plaintiffs appeal. Because we agree that the plaintiffs did not establish an injury in fact, we affirm the dismissal. We conclude, however, that the fee award was unwarranted and reverse that portion of the judgment.

Statement of Issues Presented for Review, excerpted from the Brief of Appellants:

1. Whether SPS [Springfield Public Schools] unconstitutionally compelled Plaintiffs to speak on matters of public concern and adopt its views in violation of the First Amendment.
2. Whether SPS unconstitutionally discriminated against Plaintiffs’ views when it adopted a position on current affairs and told Plaintiffs that their views were wrong.
3. Whether SPS created an unconstitutional condition of employment when it compelled speech on matters of public concern and engaged in viewpoint discrimination.
4. Whether the district court erred in finding Plaintiffs’ claims frivolous.
5. Whether the district court erred in awarding attorney fees in the amount of $312,869.50 and costs in the amount of $3,267.10 to Defendants.
6. Whether reassignment to a different judge is appropriate on any remand.

Resources:

• CourtListener docket page for Henderson v. Springfield R-12 School District
• Eighth Circuit panel opinion (September 13, 2024)
• Institute for Free Speech amicus brief
• Brief of Appellants
• Brief of Appellees

Listen to the argument here:

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