Corn v. Mississippi Department of Public Safety, No. 19-60247 (5th Cir. 2020)
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The Fifth Circuit affirmed the district court's order granting several motions for judgment on the pleadings brought by defendants in a First Amendment retaliation action. The action stemmed from the termination of plaintiffs, two state employees, for allegedly reporting an internal investigation into patrol officers' issuing non-existent traffic violations.
The court held that Eleventh Amendment sovereign immunity barred plaintiffs' claims. The court also held that the district court correctly dismissed plaintiffs' section 1983 claim for retaliation in violation of First Amendment rights for failure to allege sufficient facts that plaintiffs spoke as a citizen on a matter of public concern.
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