Jannease Johnson v. DC
CourtCourt of Appeals for the D.C. Circuit
Date FiledJuly 24, 2026
Docket24-7140
StatusPublished
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Full Opinion
United States Court of Appeals
FOR THE DISTRICT OF COLUMBIA CIRCUIT
Argued November 21, 2025 Decided July 24, 2026
No. 24-7140
JANNEASE JOHNSON,
APPELLEE
v.
DISTRICT OF COLUMBIA, ET AL.,
APPELLANTS
Appeal from the United States District Court
for the District of Columbia
(No. 1:20-cv-02944)
Stacy Anderson, Senior Assistant Attorney General, Office
of the Attorney General for the District of Columbia, argued
the cause for appellants. With her on the briefs were Brian L.
Schwalb, Attorney General, Caroline S. Van Zile, Solicitor
General, Ashwin P. Phatak, Principal Deputy Solicitor
General, and Thais-Lyn Trayer, Deputy Solicitor General.
Joseph M. Hannon Jr. argued the cause for appellee. With
him on the brief was Daniel S. Crowley.
Before: PILLARD and WALKER, Circuit Judges, and
EDWARDS, Senior Circuit Judge.
2
Opinion for the Court filed by Circuit Judge PILLARD.
PILLARD, Circuit Judge: In her 28th year of service
working for the D.C. Department of Corrections, Sergeant
Jannease Johnson was fired. She contends that her supervisors
fired her in retaliation for speech protected by the First
Amendment and the D.C. Whistleblower Protection Act—
namely, sharing emails she received in the course of her work
with her union’s attorneys and a journalist, and giving an
interview to a local news network about D.C. prison conditions
during the COVID-19 pandemic. She brings a damages action
against the officials responsible for her firing. The defendant
officials moved for summary judgment on grounds of qualified
immunity. The district court denied the motion in part. The
officials now bring an interlocutory appeal, reasserting
qualified immunity.
We reverse in part and affirm in part. The officials
committed no constitutional violation if they fired Johnson for
sharing confidential emails. But on the record evidence as the
district court assessed it on summary judgment, there is a
material factual dispute as to whether one official violated the
First Amendment by firing Johnson for granting a press
interview. The law clearly establishes Johnson’s right to speak
on matters of public concern without retaliation when her
government employer lacks a countervailing interest in her
silence, so if Johnson carries her burden at trial, the defendant
official has no entitlement to qualified immunity.
I.
A.
Sergeant Jannease Johnson worked at the D.C. Department
of Corrections (the Department) from 1992 to 2020. By March
2020, she was serving as Lead Correctional Officer in the D.C.
3
Jail and as Adjustment Board Chair of an inmate disciplinary
body. In her Board role, Johnson received emails from the
Department’s internal listserv notifying select staff of incidents
raising safety or disciplinary concerns.
Johnson was also an elected leader of the correctional
officers’ union, serving as Executive Secretary of the Fraternal
Order of Police Department of Corrections Labor Committee
(Union). As the COVID-19 pandemic surged, Johnson grew
critical of what she believed were serious lapses in the
Department of Corrections’ responses. She and other Union
leaders started meeting regularly with the Union’s attorneys to
discuss whether the Department’s policies adequately
protected staff and inmates. Johnson also began forwarding
Department emails on the topic from her official Department
account to the Union attorneys. The emails included
information about the unavailability of masks for staff,
officers’ exposure to infected inmates, and the lack of
quarantine and contract tracing measures. Union attorneys
used information that Johnson provided in an amicus brief
challenging prison conditions, in multiple Union filings
alleging that the Department engaged in unfair labor practices
related to the pandemic, and in a class-action challenge to
Department workplace-safety practices.
On April 22, inmates at the D.C. Jail staged a protest over
the Jail’s conditions by rejecting the food brought to their cells.
Johnson received an email on the Department’s safety listserv
with the subject line “Planned use of force” discussing the
Jail’s response to the protest. Johnson forwarded that email to
the Union’s attorneys, who then forwarded the email to a local
reporter. The reporter included Johnson’s email in a message
asking for comment from a communications official from the
Department. The communications official passed on the
message to the Department’s Deputy Director, Wanda Patten,
4
who replied that Johnson had violated the Department’s
policies by forwarding the email outside the Department.
The Department then launched an investigation into
Johnson’s email usage since the start of the pandemic. Three
days later, “pending investigation into misconduct” on
Johnson’s part, the Department removed Johnson from her post
as Adjustment Board Chair. Johnson v. D.C., 726 F. Supp. 3d
8, 20 (D.D.C. 2024).
On April 28, an attorney for the Union notified the
Department that Johnson had agreed to be interviewed by a
local news station, WUSA 9. Patten received a copy of the
Union’s email. Statements from Johnson’s interview were
recorded for a news segment and published on May 1 in “an
article critical of [the Department’s] response to the growing
pandemic.” Id.
Two weeks later, the Department completed its
investigation regarding the emails, concluding that Johnson
had forwarded twenty-two emails to the Union’s attorneys and
thereby “violated [the Department’s] policies and the Health
Insurance Portability and Accountability Act (‘HIPAA’).” Id.
Patten received draft removal paperwork for Johnson on May
5 and issued Johnson a notice of proposed removal from her
job on May 29. The notice charged Johnson with violations of
D.C. and Departmental regulations and confidentiality policies.
A hearing officer reviewed the proposed removal and
recommended a different outcome: not a termination, but a
reprimand or suspension in light of the circumstances of the
pandemic, Johnson’s long and otherwise unblemished record,
and the D.C. Whistleblower Protection Act. Department
Director Quincy Booth reviewed the recommendation and
“remanded the case” to the hearing officer, asking her to
“reevaluate the materials presented” and “conclude” that
5
Johnson violated the Department’s rules and regulations
prohibiting unauthorized disclosures as well as HIPAA. Id.
(quoting Booth Memorandum 1 (J.A. 390)). On remand, the
hearing officer found no violation of HIPAA when Johnson
shared health information with the Union attorneys for
purposes of obtaining legal advice, but she agreed with Booth
that Johnson had violated the Department’s rules and policies
when Johnson’s attorneys shared information with the media.
Second Hoffman-Peak Memorandum 2-3 (J.A. 405-06). The
hearing officer ultimately concluded that termination was
“supported” and “reasonable.” Johnson, 726 F. Supp. 3d at 21
(quoting Second Hoffman-Peak Memorandum 5 (J.A. 408)).
Booth then issued a notice terminating Johnson’s employment.
B.
Johnson filed suit in D.C. Superior Court against Patten,
Booth, and the Department. As relevant here, she claimed that
Patten and Booth violated her First Amendment rights and
sought relief under 42 U.S.C. § 1983. Defendants removed the
case to federal court, where Johnson defeated a motion to
dismiss. Following discovery, the parties cross-moved for
summary judgment. On the First Amendment claim, the
district court denied both motions, holding that Johnson raised
triable issues of fact material to the constitutional claim and
that the individual defendants lacked qualified immunity.
Defendants sought reconsideration of that ruling, which the
district court denied.
The individual defendants immediately appealed.
II.
Johnson moved to dismiss the appeal for lack of
jurisdiction. A motions panel of this court deferred decision of
the motion in favor of our consideration of the jurisdictional
6
question together with the merits of the qualified immunity
appeal. We accordingly begin by addressing jurisdiction.
“An order denying a motion for summary judgment is
generally not a final decision within the meaning of [28 U.S.C.]
§ 1291 and is thus generally not immediately appealable.”
Plumhoff v. Rickard, 572 U.S. 765, 771 (2014). But a different
rule applies “when the summary judgment motion is based on
a claim of qualified immunity.” Id. In such a case, the
collateral order doctrine applies, and the district court’s order,
“to the extent that it turns on an issue of law, is an appealable
‘final decision’ within the meaning of . . . § 1291.” Mitchell v.
Forsyth, 472 U.S. 511, 530 (1985); see Plumhoff, 572 U.S. at
772. We thus have jurisdiction to review the district court’s
legal conclusions on qualified immunity, accepting as
established “all of the conduct which the [d]istrict [c]ourt
deemed sufficiently supported for purposes of summary
judgment.” EIG Energy Fund XIV, L.P. v. Petroleo Brasileiro,
S.A., 104 F.4th 287, 293 (D.C. Cir. 2024) (quoting Behrens v.
Pelletier, 516 U.S. 299, 313 (1996)).
The limited scope of our review bears emphasis. At this
interlocutory stage, we have no power to review those
“portion[s] of [the] district court’s summary judgment order
that . . . determine[] only a question of ‘evidence sufficiency,’
i.e., which facts a party may, or may not, be able to prove at
trial.” Johnson v. Jones, 515 U.S. 304, 313 (1995). We thus
treat as conclusive for current purposes the district court’s
determinations on the sufficiency of the evidence to raise
material issues of fact precluding summary judgment. Our
consideration focuses on the clarity of the relevant law as
applied in the circumstances before us.
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III.
We review de novo the district court’s conclusions of law
supporting a denial of qualified immunity. Youngbey v. March,
676 F.3d 1114, 1117 (D.C. Cir. 2012). To overcome a defense
of qualified immunity, a plaintiff must show that defendants’
“conduct violated a [federal] right” and that “the right in
question was clearly established at the time of the violation.”
Tolan v. Cotton, 572 U.S. 650, 656 (2014) (internal quotation
marks and citations omitted) (modification in original).
Johnson claims a violation of her First Amendment right
to communicate as a citizen on a matter of public concern.
“The First Amendment limits the ability of a public employer
to leverage the employment relationship to restrict” or punish
its employees’ free speech. Garcetti v. Ceballos, 547 U.S. 410,
419 (2006). Although “[g]overnment employers, like private
employers, need a significant degree of control over their
employees’ words and actions,” they are also bound to respect
“the liberties [government] employees enjoy in their capacities
as private citizens.” Id.
The Supreme Court developed a framework for balancing
the interests of the government and its employees in Pickering
v. Board of Education of Township High School District 205,
391 U.S. 563 (1968). Under the four-part Pickering test, an
employee bringing a First Amendment retaliation claim must
show that
(1) she ‘spoke[] as a citizen on a matter of public concern’;
(2) her interest in commenting on matters of public
concern outweigh[ed] the government’s ‘interest in
promoting the efficiency of the public services it performs
through its employees’;
8
(3) ‘her speech was a substantial or motivating factor in
prompting the retaliatory or punitive act’; and
(4) she can ‘refute the government employer’s showing, if
made, that it would have reached the same decision in the
absence of the protected speech.’
Breiterman v. U.S. Capitol Police, 15 F.4th 1166, 1176 (D.C.
Cir. 2021) (first modification in original) (quoting Wilburn v.
Robinson, 480 F.3d 1140, 1149 (D.C. Cir. 2007)). The first
and second factors involve questions of law, while the third and
fourth factors present questions of fact. O’Donnell v. Barry,
148 F.3d 1126, 1133 (D.C. Cir. 1998).
Johnson identifies two grounds for her First Amendment
retaliation claims. First, she asserts that defendants “do not
challenge the district court’s determination that Johnson’s
disclosure to Union attorneys of internal DOC documents was
a ‘substantial’ or ‘motivating’ factor in her termination.”
Appellee Br. 34. 1 Second, she relies on the district court’s
1
On reconsideration, the hearing officer concluded that Johnson
“forward[ed] [an] email through her attorneys to the media,” holding
Johnson responsible for a Union attorney’s disclosure to a journalist.
Second Hoffman-Peak Memorandum 3 (J.A. 406). That Union
attorney, J. Michael Hannon, now represents Johnson. At oral
argument, Hannon explained that “the Hearing Officer . . . held
[Johnson] responsible for” her attorneys’ disclosure “because [the
hearing officer] was, under the rules of professional responsibility,
going to assume that since [Johnson’s] lawyer did it, [Johnson] did
it.” Oral Arg. 42:58-43:11. Hannon appeared to be referencing an
argument made by Booth when Booth remanded Johnson’s charges
to the hearing officer. See Booth Memorandum 3-4 (J.A. 392-93).
Booth asserted that the “Hearing Officer must accept that Sgt.
Johnson[’s] representative attorneys had her approval to disclose the
protected information to the media” since the attorneys would have
9
determination based on the evidence of record that “a
reasonable jury could find that Johnson’s WUSA 9 interview
was a motivating factor in Patten’s decision to fire her.” Id. at
36 (quoting Johnson, 726 F. Supp. 3d at 36).
Applying the Pickering factors, we consider whether
Johnson can demonstrate on either ground that defendants
violated her First Amendment rights in a manner clearly
established by governing precedent.
A.
Johnson cannot show that, if the jury were to find that
defendants fired her because she forwarded emails in violation
of confidentiality policies, defendants thereby violated any
clearly established First Amendment right. As to the first
Pickering factor, defendants agree that Johnson “spoke as a
violated Rule 1.2 of the District of Columbia Rules of Professional
Conduct if they had failed to consult with Johnson. Id.
Hannon’s reliance on Booth’s reasoning raises a serious ethical
concern regarding his representation of Johnson. Booth inculpated
Johnson by relying on the assumption that Hannon acted ethically.
Johnson’s interests as his client thus came into direct conflict with
Hannon’s personal interests. The hearing officer found that Hannon
had personally instructed Johnson to pass on to him internal
Department information. See First Hoffman-Peak Memorandum 6
(J.A. 385) (“Sgt. Johnson was tasked by the Hannon Law Group with
forwarding relevant email communications she received to the labor
union’s attorneys.”); e.g., S.J.A. 49; id. at 89-90. Hannon’s decision
to forward one such email to a journalist set off the inquiry that
resulted in Johnson’s firing. Appellee Br. 8-9. When asked at oral
argument about the potential conflict, Hannon asserted that Johnson
“had no idea that I was going to send [her email] to the press,” Oral
Arg. 42:10-42:39—casting doubt on Booth’s reasoning and
identifying himself as a potential fact witness in Johnson’s suit,
thereby confirming the conflict of interest.
10
citizen on an issue of public concern” about the Department’s
COVID-19 response when she sent the emails. Appellants Br.
36. But defendants vigorously contest the second factor,
asserting that the Department’s interest in the enforcement of
its confidentiality policies outweighs Johnson’s interest in
sharing with Union counsel the content of confidential emails.
On this point, defendants have the better of the argument.
The second Pickering factor requires us to identify the
speech that “contributed to [Johnson’s] discharge,” Connick v.
Myers, 461 U.S. 138, 149 (1983), and then balance Johnson’s
“interest in making her statement against ‘the interest of the
[government], as an employer, in promoting the efficiency of
the public services it performs through its employees,’” Rankin
v. McPherson, 483 U.S. 378, 388 (1987) (quoting Pickering,
391 U.S. at 568). In conducting the balancing inquiry, we
consider “the manner, time, and place of the employee’s
expression,” as well as the “context in which the dispute arose.”
Id.
We begin by defining the speech at issue. Johnson first
proposes that defendants fired her based on her “disclosure of
emails.” Appellee Br. 34. Director Booth, in his remand
message to the hearing officer, identified eleven such emails as
providing cause to terminate Johnson. Booth Memorandum 4-
8 (J.A. 393-97). The emails contained information about the
COVID status of individual inmates and staff members as well
as information from the Department’s internal Incident
Notification Mailing List. Id. The district court found
substantial “evidence in the record suggesting that Johnson did
in fact violate [District of Columbia Municipal Regulations],
[Department] policies, the collective bargaining agreement,
and the confidentiality agreement she signed in 2015” by
sending the emails. Johnson, 726 F. Supp. 3d at 33. And the
district court noted that Johnson failed to “meaningfully
11
contest” that her policy violations could establish an
“independent, legitimate reason for [d]efendants’ decision to
fire her.” Id. Although Johnson now refers to the emails as
containing “allegedly confidential information,” Appellee Br.
33, she fails to develop an argument that her disclosures were
consistent with Department policy. In any event, we lack
authority to reexamine the district court’s factual
determinations in this interlocutory appeal.
Next, we identify the government’s interest in disciplining
Johnson for her speech. An employer who takes adverse action
against an employee bears the burden to justify that action.
Baumann v. District of Columbia, 795 F.3d 209, 216 (D.C. Cir.
2015). The Department “has a strong interest in employing
officers and supervisors who can keep confidences.”
Breiterman, 15 F.4th at 1177; see Johnson, 726 F. Supp. 3d 8,
37-38 (D.D.C. 2024) (noting the Department’s “asserted
interest in maintaining the privacy of health information” of
inmates and staff). A government manager may legitimately
advance her employing agency’s interest in its confidentiality
policies by “[d]isciplining leaks—especially those that
undermine trust and interfere with administrative and security
functions.” Breiterman, 15 F.4th at 1177. And the Department
has memorialized its interest through “announced office
polic[ies]” that underscore the priority it places on
confidentiality. Connick, 461 U.S. at 153 & n.14; see Johnson,
726 F. Supp. 3d at 33, 37 (identifying confidentiality policies).
We recognize that Johnson, too, had “a strong interest
in . . . speaking to the public about safety issues” related to the
Department’s management of the D.C. Jail during the
pandemic. Baumann, 795 F.3d at 217. The district court
concluded that the evidence showed that Johnson “had a
significant interest in publicly detailing the ‘rapid and
dangerous spread of COVID-19 among [Department]
12
inmates[,] staff and their families,’ as well as insufficient
‘contact tracing,’ [the Department’s] allegedly ‘inaccurate
reporting of positive cases,’ and [the Department’s] alleged
mismanagement of the COVID crisis.” Johnson, 726 F. Supp.
3d at 36. During a rapidly escalating public health crisis, she
sought to share information concerning staff and inmate safety
inside the locked-down D.C. Jail.
But Johnson was “free to discuss [her concerns] publicly,
as [she] did” in press conferences and court filings, so long as
she refrained from passing on certain specifics—such as the
infected status of particular staff members and inmates—in
violation of Department policies. Baumann, 795 F.3d at 217.
Importantly, Johnson acknowledges that she could have raised
the same safety concerns without naming the individuals
affected. Appellee Br. 28.
Given the district court’s identification of the parties’
respective interests as supported by the record evidence, the
government’s interest in enforcing its confidentiality policies
outweighs Johnson’s interest in sharing the confidential
matters she disclosed. We accordingly hold that defendants did
not violate Johnson’s First Amendment rights if they fired her
based on her disclosure of confidential emails to the Union.
We thus reverse the district court’s denial of qualified
immunity as to that claim.
B.
Johnson may yet be able to show that Patten violated her
First Amendment rights by firing her because of her interview
with WUSA 9. As for the interview, defendants conceded the
first two Pickering factors before the district court. They
acknowledged that Johnson spoke as a private citizen and
addressed a matter of public concern—namely, the “alleged
spread of a contagious disease among [Department] personnel
13
and inmates due to [Department] mismanagement.” See
Johnson, 726 F. Supp. 3d at 35 (internal citation omitted). And
they fail to identify any statement from Johnson’s interview
that interfered with the government’s interests as an employer.
See id. at 38. That omission makes sense. As a senior
Department employee and a Union leader, Johnson had an
unusually “beneficial and well-informed” perspective to share
on the Department’s actions during the pandemic—she could
speak to the competing needs and interests of the Department,
its rank-and-file workers, and the people in its custody. Id. at
36. Johnson’s interview represents a paradigmatic case of a
government employee “speak[ing] out on an issue that [she] is
uniquely qualified to address,” O’Donnell, 148 F.3d at 1135,
and thereby supporting “informed decision-making by the
electorate,” Pickering, 391 U.S. at 572. Johnson satisfies the
first two Pickering factors as a matter of law.
On the third Pickering factor, the district court examined
the parties’ evidence and reached divergent conclusions about
the two defendants’ motivations. It concluded that no
“reasonable jury” could “find that Booth took retaliatory
actions against Johnson because of her interview” where no
evidence in the record “rebuts Defendant Booth’s sworn
statements” that he received no “notification of Sergeant
Johnson’s interview with WUSA 9’” and never learned about
the published piece. Johnson, 726 F. Supp. 3d at 39 (quoting
Booth Decl. ¶¶ 19-20 (J.A. 513)). In contrast, the district court
concluded that “a reasonable jury could find that Johnson’s
WUSA 9 interview was a motivating factor in Patten’s decision
to fire her.” Id. at 40. The court noted that Patten received an
email informing her of Johnson’s interview on April 28 and
that WUSA 9 published an article critical of the Department on
May 1. Id. at 20. It acknowledged Patten’s claim that Patten
decided to fire Johnson “at some point between April 23 and
27.” Id. at 39. The district court reasoned, however, that a jury
14
could disbelieve Patten’s factual narrative and instead infer
from other circumstances, including the email evidence, that
Patten became aware of the interview and that her displeasure
at Johnson’s public statements was a motivating factor in her
decision shortly thereafter to terminate Johnson. Id. at 40 &
n.10.
The district court’s conclusions regarding the summary
judgment record resolve our analysis of the third factor:
Johnson’s claim against Booth fails and her claim against
Patten may proceed. Defendants contest whether Johnson has
advanced sufficient evidence for a jury to conclude that Patten
had a retaliatory motive. But that factual question lies outside
the ambit of this interlocutory appeal. As explained, we lack
jurisdiction to review “question[s] of ‘evidence sufficiency,’
i.e., which facts [Johnson] may, or may not, be able to prove at
trial.” Johnson, 515 U.S. at 313.
Defendants insist that we may reconsider the district
court’s conclusions about the sufficiency of the evidence if
they are “blatantly contradicted by the record.” Scott v. Harris,
550 U.S. 372, 380 (2007). They highlight Patten’s sworn
statements that she never saw Johnson’s interview and, in any
event, agreed that Johnson should be terminated before April
28, when she received notice of Johnson’s interview. Patten
Decl. ¶¶ 19, 33 (J.A. 518-19). True, some of defendants’
evidence supports that story, and defendants may be able to
persuade a jury to reject Johnson’s claim on the third Pickering
factor. But other evidence supports Johnson’s theory. For
example, in denying defendants’ motion for reconsideration,
the district court noted that the hearing officer’s initial decision
states that Johnson’s removal “was proposed by Wanda
Patten[] on June 3.” Johnson v. District of Columbia, No. CV
20-2944, 2024 WL 3858547, at *3 n.5 (D.D.C. Aug. 19, 2024).
The district court evaluated the evidence under the summary
15
judgment standard. It was obligated to “view the evidence in
the light most favorable to the nonmoving party . . . , draw all
reasonable inferences in her favor, and eschew making
credibility determinations or weighing the evidence.”
Czekalski v. Peters, 475 F.3d 360, 363 (D.C. Cir. 2007). It
determined that Johnson had presented enough evidence to
create a genuine dispute about Patten’s motivations. Because
accepting that conclusion does not require us to indulge any
“visible fiction,” Scott, 550 U.S. at 381, we cannot on this
limited appeal dig deeper into the factual objections defendants
raise.
That leaves the fourth Pickering factor: whether Johnson
can disprove Patten’s showing that she “would have reached
the same decision in the absence of the protected speech.”
Breiterman, 15 F.4th at 1176 (quoting Wilburn, 480 F.3d at
1149). Patten has proffered evidence that she would have fired
Johnson for violating the Department’s confidentiality policies
regardless of Johnson’s interview with WUSA 9. Johnson, 726
F. Supp. 3d at 33. Before the district court, Johnson pointed to
some evidence of pretext, including the hearing officer’s initial
statements that she “believes that the proposal for [Johnson’s]
removal is retaliatory in nature” and that “removal does not
seem like a reasonable punishment” in light of “Johnson’s
record of twenty-nine years and no prior disciplines.” First
Hoffman-Peak Memorandum 7 (J.A. 386). But the district
court never specifically addressed whether a reasonable jury
could find that the WUSA 9 interview made the difference in
Patten’s decision to fire Johnson. We leave that question for
the district court to address on remand.
C.
Because Johnson may be able to demonstrate that Patten
violated her First Amendment right to speak without
16
retaliation, we turn to the second prong of the qualified
immunity inquiry: whether Johnson’s right was clearly
established at the time Patten acted. A right is clearly
established if “existing precedent . . . placed the statutory or
constitutional question beyond debate.” Hedgpeth v. Rahim,
893 F.3d 802, 806 (D.C. Cir. 2018) (quoting White v. Pauly,
580 U.S. 73, 79 (2017)).
“It is clearly established that a State may not discharge an
employee on a basis that infringes that employee’s
constitutionally protected interest in freedom of speech.”
Rankin, 483 U.S. at 383. More specifically, where an
employee speaks as citizen and “addresse[s] a matter of public
concern,” state actors are forbidden from disciplining the
employee unless they can identify “a state interest that
outweighs [the employee’s] First Amendment rights.” Id. at
388. If the state identifies no interest, then the test requires no
balancing. Punishing the employee for her speech is forbidden.
That simple equation resolves Patten’s qualified immunity
claim. As we explained, defendants acknowledge that Johnson
spoke on a matter of public concern when she participated in
the WUSA 9 interview. And defendants identify no state
interest that might weigh against Johnson’s right to give such
an interview. Patten thus lacks qualified immunity if she
indeed fired Johnson based on the interview.
We reached a similar conclusion in Navab-Safavi v.
Glassman, 637 F.3d 311 (D.C. Cir. 2011), rejecting a claim of
qualified immunity at the motion to dismiss stage where a
plaintiff plausibly alleged that nothing about her speech
meaningfully endangered any government interest. Id. at 317-
18. If the plaintiff established those allegations as true, then
“the unlawfulness [of the officer’s conduct] [would] be
apparent.” Id. at 317 (first modification in original) (quoting
17
Wilson v. Layne, 526 U.S. 603, 615 (1999)). Johnson will bear
the burden to persuade the jury of Patten’s retaliatory
motivation. If the jury finds that Patten fired Johnson for
giving an interview to WUSA 9 without Patten persuading the
jury that she would have fired Johnson even absent the
interview, then Johnson will be entitled to relief.
IV.
For the foregoing reasons, we reverse in part and affirm in
part the district court’s order of March 28, 2024, and remand
for further proceedings consistent with this opinion.
So ordered.