McArdle v. Peoria Sch. Dist. 150, No. 11-2437 (7th Cir. 2013)
Annotate this CaseMcArdle was hired as principal of Lindbergh School in 2008 with a two-year contract that allowed termination after one year with payment of severance. Lindbergh’s prior principal, Davis, was McArdle’s superior. McArdle claims that she discovered irregularities, including Davis’ use of school funds for personal purposes; improper payment to a student teacher; and circumvention of rules regarding admission of nonresidents. McArdle alleges that she received evasive responses from Davis. Davis put McArdle on a performance improvement plan in 2009, asserting parental complaints, but refusing to identify complainants. McArdle was told that the board would consider termination of her contract. McArdle consulted an attorney and filed a police report, accusing Davis of theft of school funds. She sent letters to the board, listing improprieties. Davis was excused from the meeting; the board discussed McArdle’s allegations, then voted to terminate McArdle’s contract at the end of the school year. Davis was prosecuted for theft of school funds. The district court granted defendants summary judgment on claims under the First Amendment and of breach and interference with contract. The Seventh Circuit affirmed. McArdle’s reporting of misconduct was speech as a public employee, not shielded from her employer’s response; defendants’ motives are immaterial.
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