Griffith v. Butte School District No. 1

Summary

The Supreme Court of Montana reversed summary judgment for Butte School District No. 1 and related defendants in a case involving a student's exclusion from a valedictory speech because it included references to God and Christ. The court held that the Montana Human Rights Act's exclusivity provision did not bar Griffith's constitutional claims after the Human Rights Bureau dismissed her administrative complaint and authorized suit in district court. It further held that the school district violated Griffith's First Amendment right to freedom of speech, but did not violate her federal or state constitutional right to freedom of religion.

Holdings

1. The 2007 amendments to the Montana Human Rights Act permitted Griffith to commence a civil action in district court within ninety days after receiving the Human Rights Bureau's notice of dismissal. Her claims were therefore not barred by the MHRA's exclusivity provision.
2. The claim was not moot because Griffith's complaint sought nominal damages for violation of her constitutional rights.
3. The School District violated Griffith's First Amendment right to free speech by imposing an impermissible, viewpoint-based limitation on the content of her valedictory speech.
4. The School District did not violate Griffith's rights to freedom of religion under the First Amendment or Article II, Section 5 of the Montana Constitution.
5. Because the School District violated Griffith's federal constitutional right to free speech while acting under color of state law, Griffith was entitled to seek relief under 42 U.S.C. § 1983.
6. Uggetti and Metz were immune from individual liability for actions performed within the course and scope of their official employment and were to be dismissed as individual defendants.

Questions Presented

1. Whether the 2007 amendments to the Montana Human Rights Act permitted Griffith to bring her claims in district court after the Human Rights Bureau dismissed her administrative complaint.
2. Whether the school district's refusal to permit Griffith to deliver a valedictory speech containing personal religious references violated her First Amendment right to free speech.
3. Whether the school district's refusal to permit the religious references violated Griffith's rights to freedom of religion under the First Amendment or Article II, Section 5 of the Montana Constitution.
4. Whether the action became moot because Griffith had graduated and sought no monetary damages.
5. Whether the individually named school officials were immune from individual liability under Montana law.

Disposition

reversed_and_remanded