In the United States District Court for the Western District of Missouri.
- Introduction
- Statement of uncontroverted facts
- Legal standard for summary judgment
- Argument
- Table of authorities
- Conclusion
Plaintiff Karlene Kincaid alleges that defendant River Bluffs Community College retaliated against her for exercising her First Amendment right to free speech by terminating her employment contract with the college. Plaintiff claims that the letter to the editor she wrote and the film she showed to her class are protected activity under the First Amendment. Plaintiff also contends that these protected activities were a "substantial and motivating factor" in defendant's decision to end the employment relationship.
