McCaffrey v. Chapman, No. 17-2198 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's dismissal of plaintiff's complaint alleging that the sheriff's failure to reappoint plaintiff for his political disloyalty violated his First Amendment rights to freedom of political association and speech. The court held that the Elrod-Branti exception, which permits public officials to fire certain employees for their support of a political opponent, was applicable in this instance and that the sheriff's decision not to reappoint plaintiff did not violate his First Amendment rights of freedom of political association.
The court also held that the sheriff's decision did not violate plaintiff's First Amendment right to freedom of speech under the Pickering-Connick doctrine because the balancing test weighs in favor of the sheriff.