Introduction

Skehan v. Board of Trustees of Bloomsburg State College is a pivotal case adjudicated by the United States Court of Appeals for the Third Circuit in 1978. The case revolves around Dr. Joseph T. Skehan, a non-tenured Associate Professor of Economics, who challenged the non-renewal of his contract and subsequent dismissal from Bloomsburg State College. Skehan alleged that his termination was influenced by violations of his First Amendment rights and a failure to adhere to procedural due process as outlined in the College's Academic Freedom Policy (Article 5e). The defendants, including the Board of Trustees and college administrators, contended that sovereign immunity and official immunity protected them from liability.

Summary of the Judgment

The Third Circuit Court affirmed several key findings of the district court:

• First Amendment Claim: The court denied Skehan's claim that his contract non-renewal violated his First Amendment rights, finding insufficient evidence linking his academic activism to the non-renewal decision.
• Procedural Due Process Claim (Article 5e): The court upheld the district court's ruling that Skehan was entitled to due process under Article 5e of the College's Statement of Policy, which was found to be a binding contractual agreement.
• Sovereign Immunity: The court maintained that Bloomsburg State College, as an agency of the Commonwealth of Pennsylvania, was protected under the Eleventh Amendment, thereby barring Skehan from recovering monetary damages.
• Official Immunity: Individual defendants, including college administrators, were granted official immunity from personal liability for their administrative actions.
• Attorney’s Fees: Based on recent Supreme Court decisions, the court remanded the case to consider an award of attorney's fees under the Civil Rights Attorney's Fees Awards Act of 1976.

Analysis

Precedents Cited

The judgment extensively references significant precedents that shaped the court’s decision:

• Meyers v. Pennypack Woods Home Ownership Association: Addressed the applicability of Pennsylvania's statutes of limitations to §1983 actions, influencing the court's stance on Skehan's timely filing.
• Davis v. United States Steel Supply: Reinforced the interpretation of statutes of limitations for §1983 claims, supporting the district court’s application of a six-year limitation period for Skehan's economic loss claims.
• Monell v. Department of Social Services of City of New York: Clarified that municipalities could be considered “persons” under §1983 only when official policies cause constitutional violations, impacting the sovereign immunity analysis.
• FITZPATRICK v. BITZER: Established that §1983 can abrogate state sovereign immunity when Congress explicitly authorizes such suits, though this was not applicable in Skehan's case due to subsequent legislation reinforcing immunity.
• EDELMAN v. JORDAN: Highlighted that §1983 does not implicitly waive state sovereign immunity, a principle upheld in this judgment despite challenges posed by later cases.

Legal Reasoning

The court's legal reasoning can be dissected into several key components:

• Statute of Limitations: The court determined that Skehan’s claim was governed by Pennsylvania's six-year statute of limitations for wrongful interference with contracts, thus his lawsuit was timely.
• Article 5e as a Binding Contract: The court affirmed that Article 5e constituted a contractual agreement between the College and its faculty, entitling faculty members to procedural due process in cases of contract non-renewal.
• Sovereign Immunity: Emphasizing the Eleventh Amendment, the court concluded that Bloomsburg State College was shielded from monetary damages, reinforcing the state’s sovereign immunity.
• Official Immunity of Individual Defendants: The court upheld immunity for college administrators, preventing personal liability for administrative decisions made within their official capacities.
• Attorney’s Fees: In light of the Supreme Court's decision in HUTTO v. FINNEY, the court remanded to allow consideration of attorney’s fees under the Civil Rights Attorney's Fees Awards Act of 1976.

Impact

This judgment has profound implications for several areas of law:

• Academic Employment Policies: Reinforces the contractual nature of academic freedom policies, ensuring that faculty members are entitled to procedural due process in contract non-renewal and termination cases.
• Sovereign Immunity: Affirms the protection states and their agencies enjoy under the Eleventh Amendment, limiting liability in §1983 actions unless explicitly waived by Congress.
• Official Immunity: Clarifies that individual government officials acting within their official capacities are generally immune from personal liability in discretionary functions.
• Attorney’s Fees under §1988: Aligns with Supreme Court rulings, dictating that fee awards under §1988 require a finding of bad faith, thus preventing frivolous or malicious litigation from burdensome fee transfers.

Complex Concepts Simplified

Eleventh Amendment and Sovereign Immunity

Official Immunity

§1983 Actions

Procedural Due Process

Conclusion

Skehan v. Bloomsburg State College underscores the critical balance between institutional policies protecting academic freedom and the constitutional rights of faculty members. While the court affirmed the necessity of procedural due process under contractual agreements like Article 5e, it also reinforced the robustness of sovereign and official immunities, limiting personal liability for state actors and institutions. This case serves as a foundational reference for future disputes in academic employment, clarifying the boundaries of individual rights within institutional frameworks and the extent of state immunity in civil rights litigation.