Houston Community College System v. Wilson

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Houston Community College System v. Wilson
Supreme Court of the United States
Argued November 2, 2021
Decided March 24, 2022
Full case nameHouston Community College System v. David Buren Wilson
Docket no.20-804
Citations595 U.S. ___ (more)
142 S. Ct. 1253, 212 L. Ed. 2d 303
Case history
PriorNo. 18-CV-00744, 2019 WL 1317797 (S.D. Tex. Mar. 22, 2019)(dismissing complaint); 955 F.3d 490 (5th Cir. 2020)(reversing); 966 F.3d 341 (5th Cir. 2020)(denying rehearing en banc)
Holding
Mr. Wilson does not possess an actionable First Amendment claim arising from the Board's purely verbal censure.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
Brett Kavanaugh · Amy Coney Barrett
Case opinion
MajorityGorsuch, joined by unanimous
Laws applied
U.S. Const. amend. I

Houston Community College System v. Wilson, 595 U.S. ___ (2022), is a United States Supreme Court case involving the First Amendment to the United States Constitution. The unanimous Court held that a local government board member's freedom of speech was not abridged when he was verbally censured by his colleagues.

Background

David Buren Wilson was elected a member of the Houston Community College System's board in 2013 who was censured for repeated incidences of what other members of the Board of Trustees deemed to be behavior that was not becoming of an elected official or beneficial to the HCC system.[1] Wilson filed suit in the United States District Court for the Southern District of Texas claiming that the censure was an offense to his First Amendment rights.[2]

In March 2019, U.S. District Judge Kenneth M. Hoyt dismissed Wilson's complaint, finding that no right was violated so no injury was suffered.[3] In April 2020, the United States Court of Appeals for the Fifth Circuit, reversed, with U.S. Circuit Judge W. Eugene Davis writing for the unanimous panel that Wilson had suffered "mental anguish" and criticizing the lower court for using out of circuit precedent.[4] The Fifth Circuit then deadlocked 8-8 on whether to rehear en banc, with Circuit Judges Edith Jones and James C. Ho both writing dissents criticizing the panel for creating a circuit split.[5]

Supreme Court

Certiorari was granted in the case on April 26, 2021.[6] The Court heard oral arguments on November 2, 2021, where an assistant to the Solicitor General of the United States appeared as a friend of the community college.[7]

On March 24, 2022, the Supreme Court announced judgment in favor of the community college, unanimously voting to reverse the circuit court.[8] Writing for the Court, Justice Neil Gorsuch found that Wilson's First Amendment rights were not violated by his fellow board members' censure of him because the censure did not result in any hindrance of his ability to exercise his free speech in his capacity as an elected official and member of the public. The opinion cites the fact that the use of censure by elected bodies to address the behavior and actions of their members is a practice with a long history in the United States, and it also states that the censure itself constitutes an exercise of First Amendment rights by Wilson's colleagues on the board who voted to reprimand him.[9]

References

  1. ^ Liptak, Adam (August 31, 2021). "Are Censures of Politicians a Form of Free Speech or a Threat to It?". The New York Times. p. A11.
  2. ^ Note, Recent Case: Fifth Circuit Creates Circuit Split by Finding a Legislature’s Censure Can Violate the First Amendment, 134 Harv. L. Rev. 2638 (2021).
  3. ^ Wilson v. Hous. Cmty. Coll. Sys., No. 18-CV-00744, 2019 WL 1317797, at *3–4 (S.D. Tex. Mar. 22, 2019)
  4. ^ Wilson v. Houston Community College System, 955 F.3d 490 (5th Cir. 2020).
  5. ^ Wilson v. Houston Community College System, 966 F.3d 341 (5th Cir. 2020).
  6. ^ Howe, Amy (April 26, 2021). "Justices add new cases on state secrets, free speech". SCOTUSblog. Retrieved July 5, 2021.
  7. ^ Liptak, Adam (November 3, 2021). "Supreme Court Hears Free Speech Case on Politician's Censure". The New York Times. p. A15. Retrieved October 29, 2023.
  8. ^ Liptak, Adam (March 25, 2022). "Censure of Politician Did Not Violate First Amendment, Supreme Court Rules". The New York Times. p. A16. Retrieved October 29, 2023.
  9. ^ Gorsuch, Neil (March 24, 2022). "Houston Community College System, Petitioner v. David Buren Wilson" (PDF). Retrieved March 24, 2022.

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