Jenna Amacher v. Tullahoma Housing Authority, et al.

Summary

The United States District Court for the Eastern District of Tennessee ruled on a motion for judgment on the pleadings filed by Ray Knowis and the City of Tullahoma in Jenna Amacher’s action arising from the termination of her interim executive-director employment with the Tullahoma Housing Authority. The court dismissed the First Amendment retaliation and conspiracy claim against the City, but allowed those claims against Knowis in his individual capacity and allowed Amacher’s tortious-interference-with-contract claim against Knowis to proceed. The court also declined to grant Knowis qualified immunity at this stage.

Holdings

1. Amacher plausibly alleged First Amendment retaliation because she alleged protected speech, an adverse action in the form of termination, and facts supporting an inference that refusal to dismiss her prior lawsuit was a motivating factor in the termination.
2. Amacher plausibly alleged a Section 1983 conspiracy against Knowis by alleging a shared plan and conspiratorial objective to suppress her protected lawsuit, along with overt acts that injured her.
3. Knowis was not entitled to qualified immunity on the First Amendment retaliation and conspiracy claims at the judgment-on-the-pleadings stage.
4. Amacher failed to state a First Amendment claim against the City because she did not plausibly allege that Knowis was a final policymaker with authority over her Housing Authority employment or that a City policy or custom was the moving force behind the alleged violation.
5. Amacher plausibly pleaded tortious interference with contract against Knowis.
6. Knowis was not entitled to qualified immunity on Amacher's state-law tortious-interference claim.

Questions Presented

1. Whether Amacher plausibly pleaded First Amendment retaliation and conspiracy claims against Knowis and the City.
2. Whether Knowis was entitled to qualified immunity at the judgment-on-the-pleadings stage.
3. Whether Amacher adequately pleaded municipal liability against the City under Monell.
4. Whether Amacher plausibly pleaded tortious interference with contract against Knowis.
5. Whether Knowis was entitled to qualified immunity on the state-law tortious-interference claim.

Disposition

other