Crawford v. Columbus State Community College

Summary

Thomas Crawford was an adjunct lecturer in the Department of Biological and Physical Sciences at Columbus State Community College (CSCC). In spring 2013, students at CSCC began lobbying school officials to promote Crawford to a full-time position. The students created a petition and a recommendation letter for Crawford and submitted it to the president and dean of the college. In June 2014, roughly six months after receipt of the student petition and recommendation letter, CSCC posted an opening for a full-time tenure track position in the Department of Biological and Physical Sciences. Crawford applied, but his application was passed over in favor of other candidates.

Crawford believed that CSCC officials refused to promote him in retaliation for the exercise of his First Amendment right to free speech, which allegedly consisted of orchestrating the student petition and letter of recommendation and posting literature on public bulletin boards around CSCC campus dealing with religious statements in opposition to abortion. Accordingly, Crawford filed a lawsuit in the United States District Court for the Southern District of Ohio against CSCC and various university administrators, alleging § 1983 violations of his First and Fourteenth Amendment rights.

On July 11, 2016, the Court granted in part the defendants’ Motion to Dismiss, holding that while the student petition and recommendation were not protected speech, his anti-abortion speech was protected by the First Amendment and that he had sufficiently stated a First Amendment retaliation claim based on his abortion speech. The case was dismissed with prejudice on June 7, 2018.