William Felkner v. Rhode Island College

Excerpt

The plaintiff filed a civil action against Rhode Island College and several professors and administrators, alleging that their conduct toward him when he was a student in the School of Social Work pursuing a Master of Social Work degree had violated his First and Fourteenth Amendment rights. A hearing justice of the Superior Court resolved the case on the defendants' renewed motion for summary judgment, entering judgment in favor of the defendants on all of the plaintiff's claims. On appeal, the plaintiff argued that the hearing justice had abused her discretion by considering the defendants' successive motion for summary judgment, erred by entering judgment as a matter of law in favor of the defendants on all of the plaintiff's claims, and erred by granting the defendants' motion to strike the plaintiff's claim for punitive damages. The plaintiff also argued that the doctrine of qualified immunity would not bar his suit against the defendants moving forward. The Supreme Court held that the hearing justice did not abuse her discretion by considering the renewed motion for summary judgment because the seven years that elapsed between the filing of the two motions yielded a significantly expanded record upon which to consider the presence or absence of genuine issues of material fact. After reviewing the summary judgment record de novo, the Supreme Court held there were genuine issues of material fact to be resolved by a factfinder with respect to whether the defendants' conduct: (1) infringed upon the plaintiff's right to freedom of expression (2) constituted impermissible retaliatory actions in response to the plaintiff's exercise of his right to freedom of expression (3) impermissibly compelled speech and/or (4) violated the unconstitutional conditions doctrine. With respect to the plaintiff's Fourteenth Amendment claims, the Supreme Court held that there were no genuine issues of material fact regarding the plaintiff's equal protection claim and the plaintiff's pr