Catania v. United Federation of Teachers

Background

Patricia Catania was the principal of Middle School 224, a New York City public school, until she resigned in June 2019. She alleged that the United Federation of Teachers and four of its representatives worked with teachers at the school to spread a false narrative that she opposed teaching Black history. According to the complaint, the campaign included union meetings, grievances, protests, media statements, and harassment, and ultimately contributed to her resignation. Catania and her husband, Scott Murphy, sued under 42 U.S.C. §§ 1983 and 1985, alleging violations of the First and Fourteenth Amendments. Murphy asserted derivative claims.

The defendants moved to dismiss. A magistrate judge recommended dismissal, concluding that the complaint did not adequately plead violations of Catania’s constitutional rights, a conspiracy involving state actors, or state action by the teachers. Catania and Murphy objected to the recommendation.

Court’s Analysis

The court held that Catania did not adequately plead a Fourteenth Amendment due-process claim based on her job. The complaint did not allege that she had tenure, a contract guaranteeing continued employment, or another legal entitlement to remain principal. The court therefore did not need to decide whether she had been constructively terminated or denied due process.

The court also rejected Catania’s “stigma-plus” theory. Even assuming that the complaint adequately alleged reputational harm and a related employment loss, it did not allege that she was denied an adequate process for clearing her name. The court concluded that the availability of a New York Article 78 hearing supplied the required post-deprivation process, whether or not Catania sought one.

The court rejected the First Amendment claims as pleaded. The First Amendment does not protect a person from reputational damage, and the complaint did not allege that Catania herself spoke or engaged in protected expression on a matter of public concern. The court therefore concluded that the complaint did not state a First Amendment retaliation claim.

The court sustained Catania’s objections to portions of the recommendation concerning conspiracy and state action. It concluded that the recommendation had examined the wrong alleged conspiracy by focusing on the Department of Education rather than the alleged cooperation between the union defendants and the school’s teachers. The court also held that the recommendation used an incorrect standard for determining whether public employees acted under color of state law. Nevertheless, because the complaint failed to adequately plead a constitutional violation, those issues did not affect dismissal of the claims.

The court likewise dismissed Catania’s claims under § 1985 because those claims depended on alleged violations of her First and Fourteenth Amendment rights, which were not adequately pleaded. The court sustained objections to the recommendation’s analysis of conspiracy, state action, and whether a comparator was required to plead discriminatory purpose. It explained that discriminatory intent may be alleged directly, including through alleged slurs or biased statements. The court did not analyze the equal-protection claim in detail because the defendants had not moved to dismiss it.

Disposition

The court granted in part and denied in part the defendants’ partial motion to dismiss. It dismissed Catania’s § 1983 and § 1985 claims based on alleged violations of her Fourteenth Amendment due-process rights and First Amendment rights. It also dismissed Murphy’s derivative claims and did not grant leave to amend those claims because amendment would be futile.

The court granted Catania leave to file an amended complaint concerning her § 1983 and § 1985 claims. The amended complaint was due within fourteen days of the order. The court denied the defendants’ motion to dismiss the requests for attorneys’ fees and punitive damages, explaining that those requests were not independent causes of action subject to dismissal at that stage. Judge Woods entered the order on February 8, 2024.