On August 23, 2025, the Seventh Circuit Court of Appeals affirmed an earlier ruling for Township High School District 211 in Hedgepeth v. Britton, et al., concerning the district’s dismissal of a high school teacher in connection with divisive comments posted on social media. The court ruled that the school district’s interest in maintaining workplace efficiency and preventing disruption outweighed Hedgepeth’s First Amendment rights.
Background
Jeanne Hedgepeth, a social studies teacher at Palatine High School, was terminated after posting inflammatory comments on Facebook during the nationwide protests following George Floyd’s death in 2020. Hedgepeth had a history of disciplinary issues, including two prior suspensions for using profanity in the classroom. Her Facebook posts, which were visible to a large audience of former students, included comments perceived as racially insensitive and jokes about using force against protestors. Despite setting her account to private, the posts were copied and circulated widely online, leading to complaints from community members and media inquiries.
The school district conducted an investigation and found that Hedgepeth’s actions violated multiple district policies, including those governing social media conduct and professional relationships, and prevented her from effectively performing her job as a teacher. Following a dismissal hearing in which the hearing officer found that Hedgepeth’s posts were disruptive and her conduct was irremediable, the board of education voted to terminate Hedgepeth’s employment. Hedgepeth challenged her termination, arguing that her posts were protected under the First Amendment. The district court disagreed, ruling in favor of the school district on summary judgment. Hedgepeth appealed.
Ruling
The Seventh Circuit Court of Appeals affirmed the district court’s decision, agreeing that the school district’s interest in addressing disruptions and preventing future ones outweighed Hedgepeth’s First Amendment interests. The court applied the balancing test from the U.S. Supreme Court’s 1968 decision in Pickering v. Board of Education, which considers whether a public employee’s speech is protected by weighing the employee’s interest in commenting on matters of public concern against the employer’s interest in workplace efficiency. The court noted the significant disruption caused by Hedgepeth’s posts, including community outrage and media attention, which justified her termination. The court emphasized that Hedgepeth’s role as a teacher required maintaining public trust and that her posts undermined her effectiveness in that role.
Lessons for School Districts
The appellate court’s decision highlights the challenges public school districts face in balancing teachers’ free speech rights with the need to maintain a conducive learning environment. While teachers and other public employees retain their First Amendment rights, they also accept certain limitations on those rights when their speech has an effect on the workplace.
This ruling highlights the importance of clear policies regarding employee conduct on social media and the potential consequences of violating such policies. It also underscores the need for districts to document and address disruptions caused by employees’ actions to support disciplinary decisions and set the stage for progressive discipline when appropriate.
