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Houston Community College System v. Wilson

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Supreme Court of the United States
Houston Community College System v. Wilson
Term: 2021
Important Dates
Argued: November 2, 2021
Decided: March 24, 2022
Outcome
Reversed
Vote
9-0
Majority
Neil Gorsuch • Chief Justice John Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett

Houston Community College System v. Wilson is a case decided by the Supreme Court of the United States on March 24, 2022, during the court's October 2021-2022 term. The case was argued before the court on November 2, 2021. The court reversed the decision of the U.S. Court of Appeals for the 5th Circuit, holding David Wilson, the defendant, did not have an actionable First Amendment claim. Justice Neil Gorsuch wrote the unanimous opinion. Click here for more information about the ruling.

HIGHLIGHTS
  • The case: David Wilson was an elected member of the Houston Community College System's board of trustees. In 2017, Wilson alleged that some members had violated the board's bylaws and publicly criticized some of the board's and the school's actions. Wilson filed two lawsuits in state court to stop the actions. The board censured Wilson for his actions, barring him from holding officer positions with the board and requiring Wilson to cease and desist. Wilson claimed the censure violated his constitutional rights to free speech and equal protection. The case moved to U.S. district court and the court dismissed the case, holding that Wilson had not demonstrated an actual injury and therefore did not have legal standing to continue the suits. On appeal, the U.S. Court of Appeals for the 5th Circuit reversed the ruling and remanded the case for further proceedings. Click here to learn more about the case's background.
  • The issue: The case concerned free speech protections and limitations on an elected governing body’s authority to censure a member for their speech.
  • The questions presented: "Does the First Amendment restrict the authority of an elected body to issue a censure resolution in response to a member's speech?"[1]
  • The outcome: In a unanimous opinion, the court reversed the judgment of the U.S. Court of Appeals for the 5th Circuit, holding the board had not violated Wilson's right to free speech by censuring him.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit. To review the lower court's opinion, click here.[2]

    Timeline

    The following timeline details key events in this case:

    Background

    David Wilson was an elected member of the Houston Community College System's board of trustees. He was elected to the board in 2013. In 2017, Wilson made allegations that other members had violated the board's bylaws, that another trustee did not live within their elected trustee area, and criticized the board's decision to fund a campus in Qatar. Wilson made public complaints by arranging robocalls regarding the Board’s actions and during interviews with a local radio station. Then, the board allowed a member to vote on a matter via videoconference. Wilson said that the board's bylaws did not allow that voting method. Wilson filed a lawsuit against the school ("HCC") and individual board members in state court, asking the court to declare that the vote was illegal and to prohibit that vote. Then, according to the United States Court of Appeals for the 5th Circuit opinion, the board allegedly excluded Wilson from an executive session. Wilson filed a second lawsuit in state court against the school and board members, claiming that he was unlawfully excluded. Wilson hired a private investigator to verify where one of the trustees lived and he hired a private investigator to investigate the school. He maintained a website where he published his concerns about the board and the school's actions. The board censured Wilson for violating the board's bylaws and for not acting in the best interests of the college and board. The censure resolution barred Wilson from holding officer positions with the board and from having related travel costs reimbursed, and stipulated that Wilson would be subject to further disciplinary action unless he ceased and desisted his censured actions. Wilson amended his original complaint in state court to state that the censure violated his constitutional rights to free speech and equal protection.[2][3]

    The school and trustees moved the case to the United States District Court for the Southern District of Texas to settle the constitutional challenges that Wilson had raised. Wilson asked for the case to be remanded back to the state court. The Southern District of Texas denied the request. Wilson amended his complaint to remove the names of the individual trustees. HCC moved for the case to be dismissed. The district court granted the dismissal based on a lack of jurisdiction and holding that Wilson had not demonstrated an actual injury caused by HCC and therefore did not have standing to continue his suit. Wilson appealed to the United States Court of Appeals for the 5th Circuit.[2]

    In August 2019, Wilson resigned from the board. In the November 2019 election, Wilson ran as a candidate in the race for trustee of a different trustee district. He was defeated in the runoff election in December 2019.[2]

    On appeal, the 5th Circuit held that the board had violated Wilson's right to free speech by censuring him and concluded that his claim for damages did have standing. In 2020, the court reversed the district court's ruling and remanded the case for further proceedings.[2][3] The HCC appealed to the U.S. Supreme Court on December 11, 2020.

    Questions presented

    The petitioner presented the following questions to the court:[1]

    Questions presented:
    “ Does the First Amendment restrict the authority of an elected body to issue a censure resolution in response to a member's speech?[4] ”

    Oral argument

    The U.S. Supreme Court heard arguments in the case on November 2, 2021.

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]

    Outcome

    In a unanimous opinion, the court reversed the judgment of the U.S. Court of Appeals for the 5th Circuit, holding the board had not violated Wilson's right to free speech by censuring him. Justice Gorsuch delivered the opinion of the court.[7]

    Opinion

    In the court's unanimous opinion, Justice Gorsuch wrote:[7]

    “ [T]he only adverse action at issue before the Court is itself a form of speech from Mr. Wilson’s colleagues that concerns the conduct of public office. The First Amendment surely promises an elected representative like Mr. Wilson the right to speak freely on questions of government policy, but it cannot be used as a weapon to silence other representatives seeking to do the same. The censure at issue before us was a form of speech by elected representatives concerning the public conduct of another elected representative. Everyone involved was an equal member of the same deliberative body. The censure did not prevent Mr. Wilson from doing his job, it did not deny him any privilege of office, and Mr. Wilson does not allege it was defamatory. Given the features of Mr. Wilson’s case, the Board’s censure does not qualify as a materially adverse action capable of deterring Mr. Wilson from exercising his own right to speak. ... Neither history nor this Court’s precedents support finding a viable First Amendment claim here[4] ”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 U.S. Supreme Court, "20-804 HOUSTON COMMUNITY COLLEGE SYSTEM V. WILSON: Questions Presented," accessed April 26, 2021
    2. ↑ 2.0 2.1 2.2 2.3 2.4 United States Court of Appeals for the 5th Circuit, Wilson v. Hous. Cmty. Coll. Sys., decided April 7, 2020
    3. ↑ 3.0 3.1 SCOTUSblog, "Sovereign immunity, legislative censure and another habeas question," April 21, 2021
    4. ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 2, 2021
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 2, 2021
    7. ↑ 7.0 7.1 Supreme Court of the United States, Houston Community College System v. Wilson - Opinion, decided March 24, 2022
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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