The wrong ruling for whistleblowers

[tag]Richard Ceballos[/tag] seemed like a fairly classic example of a [tag]whistleblower[/tag]. He was a deputy district attorney in Los Angeles who reviewed a warrant in a criminal case. Ceballos raised objections to flaws in the warrant, put those concerns in writing, but was overruled by his superiors. Later, he testified in the case about his original observations for the defense.

Ceballos was then turned reassigned and down for a promotion, prompting him to file suit, claiming that the District Attorney’s office punished him for exercising his free speech, which should have been protected under whistleblowers’ protection.

Today, the [tag]Supreme Court[/tag], in a narrow 5-4 ruling, disagreed.

The Supreme Court today narrowed the First Amendment protections for public employees who reveal perceived wrongdoing they happen to observe in the course of doing their jobs.

The decision enhances the ability of governments at all levels to punish employees for speaking out, shielding officials in many instances from lawsuits for violating the right to free speech. […]

In a 5-4 opinion , Justice Anthony M. Kennedy said the courts should not be displacing “managerial discretion” over the behavior of employees by intruding in decisions that are wholly related to the workplace. “Employers have heightened interests in controlling speech made by an employee in his or her professional capacity…. Official communications,” he said, “have official consequences.”

This, it seems to me, was the wrong call, which wouldn’t have happened a year ago.

For example, this 5-4 ruling would likely have gone the other way were it not for Sandra Day O’Connor’s retirement. Recent Supreme Court rulings had been expanding constitutional protections for employees who speak out; this one interrupted that progress. What was the difference? In this case, Garcetti v. Ceballos, Samuel [tag]Alito[/tag], and not [tag]O’Connor[/tag], was the deciding vote. (The remaining five justices in the majority were, of course, Roberts, Scalia, Thomas, and Kennedy.)

As for the substance of the case, Kennedy said employees could still speak out as citizens, but not as a public employee who speaks “pursuant to official duties.” So, a teacher’s letter to a local newspaper addressing school funding issues is protected, but a deputy district attorney’s memorandum is not because he was a public employee engaging in on-the-job speech.

Does this strike you as terribly disjointed? Isn’t the ruling practically a yes-man protection act? As Marty Lederman explained, “[I]f one’s duties are to expose wrongdoing in the workplace, such exposure is entitled to no constitutional protection.”

So, [tag]whistleblowers[/tag], when you work in government and see errors of fact and judgment, don’t tell your superiors because they can legally hurt your career if they disagree with your analysis. Instead, just leak it to the media and let the process work itself out.

I cann’t say it any better than commenter scribe at TalkLeft ,

So, let me get this straight.

If (a) I’m a public employee and (b) my employer decides “reporting wrongdoing” to my superior is a part of my job description and (c) I report wrongdoing to my superior and (d) my superior doesn’t like my report, then (e) I can get fired for doing my job?

But, if on the other hand (a) I’m a public employee and (b) my employer decides “reporting wrongdoing” to my superior is a part of my job description and (c) I report wrongdoing to, say, a blog or a newspaper and (d) my superior doesn’t like my report, then (e) I can’t get fired because what I did wasn’t part of doing my job, but (f) I can probably get fired for not doing my job because I (1) should have reported the wrongdoing to my superior and (2) been fired for doing my job as described above?

So, in other words, if what you report displeases the boss, you get canned, regardless….

Well, thank you Strip Search Sammy! What a wonderful means to bury criminality! I hear W’s sending over a fruit basket.

  • Employers have heightened interests in controlling speech made by an employee in his or her professional capacity.

    OK, fine. There’s some merit to that.

    Who’s the “employer” of a deputy district attorney? The people, fuckwads!!!

    If the DA’s underling testifies, truthfully, about how badly the DA is screwing up his job, I as the DA’s employer (I elected him, I pay his salary through taxes) need to know about this.

    And so the concept of the “imperial presidency” seeps throughout the government like a cancer: imperial congressmen, imperial DAs, … Whoever is in power is now entitled to hold power and throttle any challenges to his power, by any means necesary.

    Who’d have guessed that popular sovereignty would turn out to be like virginity: now that we’ve lost it, we’ll never get it back.

  • what would expect from Bush appointees other than “bubble protection”? (or is that bubble-wrap?)

  • Every gutless Beltway Democratic whore who bent over for Bush on these Court nominations should be proud today.

  • Not to be contrary, but the Court seems to have held that there is no Constitutional protection of an employee’s statements made in the course of her employment. I’m not sure that’s terribly exciting news, since there wasn’t such a protection before this decision. In effect, the SCOTUS simply refused to find such a protection. As the court pointed out, there are laws out there to effect this same protection, such as the Whistleblower’s Protection Act, etc. I’m comfortable with the idea that laws can satisfy this need, even if the present laws fail to do so adequately, without finding a constitutional right.

    Either way, do we, as a society, really expect politicians to retain employees who “rat them out”? Maybe this makes sense in corporations (although, even then, only to prevent specific executives or managers from protecting themselves at the expense of the company), but in politics? No way. Politicians make way too many tough decisions to be expected to function with someone they do not trust inside their office. To find this right would have been to suppose that the judiciary can compel a politician to accept into his or her staff a known disloyal. When we think the politician is corrupt and the “disloyal” is virtuous, that sounds like a great idea. But that won’t be he case all the time. What if the whistleblower was wrong? Can we fire them then, or do we have to keep letting them back? What if the “whistleblower” is a GOP plant in a Dem DA’s office, simply rooting around looking for mistakes to expose (or vice versa), but still did his job satisfactorily? Would we even be having this argument? Of course not, and it’s a little far fetched to suppose that any political officeholder could function without unilateral control over their staff.

    If an employee has the scruples to report his or her boss for malfeasance, good for them, we should all be so virtuous. But don’t ask that same boss to welcome that employee back as if nothing had happened. That’s a recipe for trouble, since what employer could really welcome that person back to a sensitive position? To a position of trust? Sometimes, to do the right thing, you gotta quit your job.

  • “I hold it that a little rebellion now and then is a good thing, and as necessary in the political world as storms in the physical.” – – – Thomas Jefferson, 1787.

    Once again, the viscous, goo-like mentality that is Kid George’s Amerika brings yet another reason as to why Mr. Jefferson’s words should be remembered. Now personally, I’d neither actively nor passively contemplete the encouragement of open rebellion However, I’m no longer of the mind to interfere in such a process, if there should arise within the general population the overt willingness to engage this current administration upon the fields of valor. Such, it seems, may be the only logical course, in the end, when the government starts punishing those who keep their faith with society, and rewarding those who do not….

  • Quite frankly, I found during my sentence to “government service” that making a complaint to one’s superiors was like complaining to a mugger for being robbed. I routinely just gave what I ran across to the press. Fortunately for me, I had the perfect cover to do so, since a reporter for the Sacramento Bee was a fellow member of the local scale-modeling club, a venue that would never attract the scrutiny of those who live in the category of “culprit.”

    I think the funniest one was when Jerry Brown (who I won’t be voting for this next Tuesday, since I don’t vote for obvious shitheads) killed the mating season of the little black birds in Capitol Park. This happened in the late winter of 1976, when Brown, in the company of the Director of General Services, came walking out of the capitol building and heard country-western music on the speakers in the trees of the park. He commented how nice it would be if they could play a tape of the bird songs of native California birds. That afternoon, a Staff Services Analyst was called to the Director’s office and given the assignment. He then worked full-time for six weeks calling birders and getting tapes and getting them all recorded onto a master tape. It began playing in the park the week the little black birds who live there arrived, with the males setting up territories for mating and such. Except they all flew away!! There was no mating season that year in Capitol Park (which pleased some people who didn’t have to duck the little black Stukas dive-bombing them to stay away from the trees). The analyst was given the assignment of finding out how this happened. It turned out that 80 percent of the bird calls on the tape were birds who were the Sworn Enemies of the little black birds, who had fled for their lives. The report was naturally sent to the Round File (Number 13). My friend the analyst however, kept a copy, and was pissed off about the situtation sufficiently that he didn’t mind making me a copy, which then made its way to the model club meeting, and then on to the front page of the Sacramento Bee, questioning Brown’s environmentalism. Given the gaggle of new age morons he had “doing environmentalism”, the subsequent black eye resulted in the more egregious of the bunch getting their walking papers.

    While that’s a very small example, I can see my good friend Chuck Spinney’s career at the Versailles-on-the-Potomac (aka the Pentagon) going nowhere fast, had he had to operate under this sort of wrongheaded ruling during his years there shining a flashlight on that swamp. All the Court has done is provide the biggest CYA ever made to the fifth-rate morons who populate the levels GS-12 and above in the Federal Government.

    This is not good news.

    And people wonder why I think Hollyweird was a better alternative to “public service.”

  • One thing I neglected to say in the story about Jerry and the birds: during the course of his initial research, the analyst discovered that many of the calls would possibly have the effect they turned out to have, and warned his superiors, all of whom said “the Governor wants this, do it.” So there was an attempt made to head them off before they drove over the cliff, and the result was they stepped on the gas after the warning.

  • There is a case pending in Federal District Court against Penn State which may eventual provide some insight into the effect today’s ruling will have on academic speech.

    In July of 2003 Mitchell Aboulafia was hired by Penn State as head of the philosophy department and given tenure and the rank of full professor. During his first year as department head a female graduate student complained to him about the harassing behavior of a senior faculty member. According to the student newspaper, the Daily Collegian,

    Aboulafia states in his lawsuit that he received a report of discrimination and harassment from a female graduate teaching assistant. The report involved the same professor who had been accused of serious misconduct by others, according to court documents.
    “The particular graduate teaching assistant had been harassed so severely that she felt it necessary to turn off her phone and sequester herself in her apartment for fear of further contact with the harassing faculty member,” Aboulafia said, according to court documents.
    Aboulafia said in his brief that the harassment violated not only Penn State policies, but also federal and state law prohibiting discrimination in employment and education.

    Aboulafia tried on several occasions to report this conduct to his immediate superiors Dean Susan Welsh and Associate Dean Ron Fillippie of the College of Liberal Arts. They dismissed the allegations out of hand.

    After being rebuffed with in the College,

    …, on March 11, 2004, Aboulafia contacted the director of Penn State’s Affirmative Action Office, Kenneth Lehrman, to get advice on what he should do. According to the legal brief, he said Lehrman expressed concern and told Aboulafia he had acted properly in contacting the office.

    Dean Welsh response to this was swift.

    On March 15, 2004, Welch allegedly wrote an e-mail message to Aboulafia, declaring it was “inappropriate” for him to contact the Affirmative Action Office and indicating that such matters should be kept within the office, according to Aboulafia’s complaint.
    Three days later, Aboulafia was terminated from his position as department head.

    He was terminated in less that a years time! (Given that Aboulafia was hired from outside of Penn State, I would surmise that he faiedl to understand the corrupt nature of the institution. See for example the University’s handling of the
    Rene Portland case.)

    Aboulafia remains a tenure faculty member. His response to Penn State action was to file a lawsuit,

    …against the university, College of the Liberal Arts Dean Susan Welch and former Associate Dean Ron Filippelli for a breach of contract, violation of the Pennsylvania Human Relations Act and violation of First and 14th amendments of the U.S. Constitution
    .

    He is asking to be reinstated as department head.

    It is his first amendment claim which was put in to question by today’s Supreme Court decision. How this is handled by the District Court will give us all some indication of how today’s decision will impact academic speech.

    It must be said however that since a department head is an at will employee of the university and, as such, his job as department head is not protected by tenure suit the outcome of this suit will not shed light the first amendment issue with regard to classroom speech or research.

    For some reason the links aren’t working above. Here they are
    http://www.collegian.psu.edu/archive/2006/04/04-27-06tdc/04-27-06dnews-09.asp
    http://www.usatoday.com/sports/college/womensbasketball/2006-05-11-jennifer-harris_x.htm?POE=SPOISVA

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