Case Citator › Spiegla v. Hull

Spiegla v. Hull

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Seventh Circuit
Citation
371 F.3d 928
Decided
Confirmed treatments
1
Flagged citations read
54 of 54
Citing cases (total)
54
Treatment dates
2007
Overruled in part
A reviewed court has overruled part of this case’s holding. Spiegla v. Hull was overruled in part. All 54 flagged citations have been read.
More on how this was screened

The confirmed treatment is listed below. On the later appeal in the same case, the Seventh Circuit held that Garcetti v. Ceballos displaced Spiegla's conclusion that the officer spoke as a citizen when she reported a possible prison security breach to a superior. Other parts of the 2004 opinion, including its retaliation causation rule, continued to be cited.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

54 later cases cite Spiegla v. Hull; 54 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Spiegla v. Hull?

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Treatments

Overruled in part

  • The Seventh Circuit rejected Spiegla's conclusion that the officer spoke as a citizen, holding that her report to a superior was speech made pursuant to her official duties.

    Spiegla v. Hull · Seventh Circuit · filed

    We acknowledged in Spiegla I that Spiegla's statements were "consistent with her general duty as a correctional officer to keep the facility secure." 371 F.3d at 939. We went on to conclude, however, that because they "were not part and parcel of her core function[ ]" to implement but not question prison security policies, "she acted beyond her employment capacity and spoke as a private citizen on a matter of public concern." Id. This focus on "core" job functions is too narrow after Garcetti, which asked only whether an "employee's expressions [were] made pursuant to official responsibilities." Garcetti, 126 S.Ct. at 1961.
    Read the full opinion on CourtListener →

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