Deeren v. Anderson, No. 21-3394 (7th Cir. 2023)
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Deputy Deeren announced his candidacy for Sheriff of Trempealeau County in 2017. In early 2018, officials within the Sheriff’s Department discovered that Deeren had failed to disclose information about his arrest record when he applied to become a deputy. Deeren had been asked in a 2015 job interview whether he had any prior contact with law enforcement; he failed to disclose that he had been arrested and charged with criminal sexual assault in 2007. After the Department learned of the arrest in 2018, Deeren was again asked about his prior contacts with law enforcement. Deeren again omitted his 2007 arrest and, when confronted, refused to answer questions about it. Then-Sheriff Anderson and Chief Deputy Reinders sought to terminate Deeren for dishonesty and insubordination. Deeren ultimately resigned from the Department and lost the sheriff’s race to Semingson, another deputy in the Department.
Deeren filed suit, alleging that Anderson, Reinders, and Semingson engaged in several retaliatory actions against him in response to his candidacy and in violation of the First Amendment. The district court granted the defendants summary judgment. The Seventh Circuit affirmed. Deeren failed to offer evidence from which a reasonable jury could conclude that any defendant engaged in a single act of unconstitutional retaliation.
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