Taylor v. City of Lawrenceburg
Taylor, a former police officer for the Town of Lawrenceburg, Indiana, ran and won an election for city council in November 2011. While running for office Taylor appeared at a campaign event in full uniform and represented on his police time sheet that he was on duty during the campaign event. As a result, the Indiana State Police conducted an investigation into his conduct and criminal charges were filed against Taylor in October 2011. The city placed Taylor on administrative leave with pay shortly after the criminal charges were filed and in early 2012 moved him to a desk position.
In the spring of 2013 Taylor signed a deferred prosecution agreement admitting to the criminal charges and agreeing to resign from the city council. The next day he issued a letter accussing the city of corruption and criminal wrongdoing. A week later, the city notified Taylor of its intent to terminate his employment and he requested a hearing. The city council voted 2 to 1 to terminate his employment and issued its finding pursuant to state law. They rebuffed Taylor's suggestion that the termination proceedings were initiated because of his letter accussing the city of wrongdoing.
Taylor filed a First Amendent retaliation claim and the district court entered summary judgment in favor of the defendants, concluding that the claim was barred by res judicata or collateral estoppel and that the individual defendants were immune because he had alleged that they had acted under authority or color of law. The Seventh Circuit reviewed the case de novo and held that the city board acted in a judicial capacity at the termination hearing. The court held that Taylor had a full opportunity to litigate before the city board and before the appeals courts and, therefore, had a full and fair opportunity to be heard on his claims. As a result, the Seventh Circuit affirmed the district court decision.