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Keywords

lawsuitdefendantappealhearingmotionsummary judgmentdue process

appealhearingmotionsummary judgmentdiscriminationdue processmotion for summary judgment

Related Cases

Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 53 Fair Empl.Prac.Cas. (BNA) 1481, 62 Ed. Law Rep. 894

Facts

Earl Bradley taught in the Pittsburgh public schools from 1964 to 1985 and developed a classroom management technique known as Learnball. Despite being directed by school officials to cease using Learnball, Bradley continued to use it, leading to an unsatisfactory rating and subsequent dismissal proceedings against him. He claimed that his suspension and termination violated his First Amendment rights and due process. After exhausting state administrative remedies, he filed a federal lawsuit, which led to the district court granting summary judgment for the defendants.

Earl Bradley taught in the Pittsburgh public schools from 1964 to 1985, last at Taylor–Allderdice High School. During his tenure he developed and was the leading advocate of a classroom management technique known as Learnball.

Issue

Did the district court err in granting summary judgment in favor of the defendants, and are Bradley's federal claims precluded by the state proceedings?

The court must decide whether Bradley's unsuccessful appeal of his termination through the Pennsylvania state administrative process and state courts precludes him from raising his federal claims here notwithstanding his explicit reservation of these claims.

Rule

A party who has been forced to litigate in state court may reserve its federal claims for federal adjudication by informing the state court of its reservation of those claims.

Analysis

The Court of Appeals determined that the district court improperly granted summary judgment after a hearing on motions in limine, which did not provide Bradley with the necessary procedural protections. The court also recognized that Bradley had validly reserved his federal claims during the state proceedings, and thus those claims were not barred by claim preclusion. However, the court held that the state determination regarding Bradley's conduct was entitled to preclusive effect.

The district court entered summary judgment against Bradley following a hearing on motions in limine rather than in the context of ruling on a motion for summary judgment.

Conclusion

The Court of Appeals affirmed in part and reversed in part the district court's decision, allowing Bradley to pursue his federal claims regarding First Amendment violations and procedural due process while upholding the state court's findings on his conduct.

The court held that Bradley had failed to state a claim for race discrimination, abuse of process, retaliation for filing a worker compensation claim, taking of a property interest without due process, or equal protection.

Who won?

The prevailing party was the defendants in part, as the court upheld the state court's findings regarding Bradley's conduct, but the court also allowed Bradley to pursue certain federal claims.

The Board thus concluded that Bradley should be dismissed under Section 1122 of the Public School Code.

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