## Facts

- Edward R. Lane served as Director of the Community Intensive Training for Youth (CITY) program at Central Alabama Community College (CACC).
- Lane audited CITY’s payroll and found that Suzanne Schmitz, a state representative, was being paid but not reporting to work.
- Lane terminated Schmitz’s employment, triggering public controversy and a federal investigation.
- Lane was subpoenaed and gave truthful sworn testimony in two federal criminal trials concerning Schmitz’s nonperformance and termination; Schmitz was convicted.
- CACC President Steve Franks later issued termination letters to 29 CITY employees, citing budget shortfalls, and then rescinded 27 terminations; Lane remained terminated.
- Lane sued under 42 U.S.C. § 1983, alleging he was fired in retaliation for his trial testimony in violation of the First Amendment.

## Issues

1. Whether a public employee’s truthful, subpoenaed trial testimony, given outside the employee’s ordinary job responsibilities, is protected speech under the First Amendment.
2. Whether qualified immunity bars damages against the public official who allegedly retaliated for that testimony.
3. Whether Eleventh Amendment immunity bars official-capacity claims seeking prospective relief.

## Decision

- The Supreme Court held that Lane’s truthful subpoenaed testimony, given outside the scope of his ordinary job duties, was speech as a citizen on a matter of public concern and was protected by the First Amendment.
- The Court concluded that the Pickering balance favored Lane because the government showed no adequate efficiency or disruption justification for retaliation.
- The Court held that Franks was entitled to qualified immunity on the individual-capacity damages claim because the right was not clearly established in the Eleventh Circuit at the time of the firing.
- The Court vacated and remanded as to the official-capacity claim for prospective relief, instructing further consideration consistent with the availability of Ex parte Young-type relief.

## Legal Principles

- Under Garcetti, speech is unprotected when it is made pursuant to an employee’s official duties; the controlling inquiry is whether the speech itself is ordinarily within the scope of the employee’s duties, not whether it concerns information learned at work.
- Truthful sworn testimony compelled by subpoena, when outside an employee’s ordinary job responsibilities, constitutes citizen speech for First Amendment purposes.
- Speech exposing corruption and misuse of public funds is a matter of public concern, and sworn testimony in judicial proceedings strengthens that characterization.
- Under Pickering, courts balance the employee’s interest in speaking as a citizen against the government’s interest in efficient public service; absent evidence of disruption, falsity, or disclosure of protected information, retaliation is unjustified.
- Qualified immunity protects officials from damages unless existing precedent clearly established the unlawfulness of the challenged conduct at the time.
- The Eleventh Amendment does not categorically bar official-capacity suits seeking prospective relief against state officials.

## Conclusion

The Court ruled that a public employee’s truthful, subpoenaed courtroom testimony outside ordinary job duties is protected by the First Amendment, but denied damages against the responsible official due to qualified immunity and remanded for further consideration of prospective official-capacity relief.


Lane v. Franks, 573 U.S. 228 (2014)