Rendell-Baker v. Kohn (2)
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School
University of Michigan *
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Course
631
Subject
Law
Date
Jan 9, 2024
Type
Pages
3
Uploaded by gemfletch
I. Facts:
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The school is a privately operated school for maladjusted high school students.
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Nearly all of the students have been referred to the school by city school committees
under a MA statute or by a state agency.
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When students are referred to the school by city committees the cities pay for the
students’ education.
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The school also receives funds from a number of state and federal agencies.
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Public funds account for 90% of the operating budget.
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Rendell-Baker claims discharge in violation of 1st, 5th and 14th Amendments
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Rendell-Baker (Plaintiff) was a teacher at a private school known as the "Center for
Independent Action" (CIA).
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CIA received government funding through a Massachusetts statute which provided
financial assistance to non-profit organizations serving educationally deprived children.
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CIA terminated the employment of Rendell-Baker and other teachers, claiming financial
difficulties and declining enrollment as reasons.
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Rendell-Baker and other terminated teachers brought a lawsuit against the school and its
administrators (Defendants), alleging that they were deprived of their constitutional rights
because CIA's decision to terminate them was influenced by their exercise of free speech.
II. Issue(s):
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Is a private school considered a “state actor” for purposes of the 14th Amendment when
it receives state financial aid and thus be subject to constitutional restrictions on its
actions?
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Does the termination of the teachers by CIA based on their exercise of free speech violate
their constitutional rights?
III. Holding:
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Unanimous: The Supreme Court held in favor of the defendants, ruling that their
picketing at the funeral was protected speech under the First Amendment.
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The Court determined that the plaintiff could not recover damages for intentional
infliction of emotional distress.
IV. Reasoning:
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The Court determined that CIA's status as a private school receiving government funding
did not automatically transform it into a state actor. While the school received financial
assistance from the government, this alone was not sufficient to make it a government
entity subject to constitutional constraints.
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The school was managed by a private board.
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The school, like the nursing homes, is not fundamentally different from many
private corporations whose business depends primarily on contracts to build
roads, bridges, dams, ships, or submarines for the government. Acts of such
private contractors do not become acts of the government by reason of their
significant or even total engagement in performing public contracts
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Analogously, although the State pays for public defenders, the relationship b/w
the public defender and client is the same as any other lawyer-client relationship.
Similarly, the relationship between the counselor and students are not changed
just because the State pays the tuition of the students.
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The Court also found that the termination of the teachers by CIA did not violate their
constitutional rights. It noted that the school's decision to terminate the teachers was
based on financial concerns and declining enrollment, not solely on the teachers' exercise
of free speech. Therefore, the termination did not amount to a violation of the First
Amendment.
V. Legal Principle(s) (Rule(s) of Law):
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The "color of state law" doctrine is a legal principle that determines when the actions of
private individuals or entities can be considered state action, making them subject to the
restrictions and protections of the U.S. Constitution.
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To determine whether the actions of a private entity can be attributed to the state, courts
often consider factors such as:
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Government Funding: The extent and nature of financial assistance from the
government can be a significant factor. If an entity is heavily reliant on
government funding, it may be more likely to be considered a state actor.
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Government Regulation and Control: The level of government regulation and
control over the entity's operations can also be important. If the government
exercises significant control over the entity, this may indicate state action.
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Public Function: Courts may consider whether the entity performs a function that
is traditionally performed by the government. If the entity is involved in providing
a service that is typically a government function, this may suggest state action.
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In the Rendell-Baker case, the Supreme Court ultimately held that receiving government
funding alone was not sufficient to transform CIA into a state actor.
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The Court emphasized that the termination of the teachers was primarily based on
the school's financial difficulties and declining enrollment, rather than being a
direct result of their exercise of free speech. Therefore, the "color of state law"
doctrine was not applicable in this case, and CIA's actions were not considered
state action subject to constitutional restrictions.
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Receipt of government funding alone does not necessarily make a private entity a state
actor subject to constitutional restrictions.
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To establish a violation of the First Amendment, there must be a clear showing that the
government was significantly involved in the private entity's decision to infringe upon an
individual's constitutional rights.
VI. Separate Opinion(s)
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Justice Marshall and Brennan dissented.
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The State has delegated to the New Perspectives School its statutory duty to
educate children with special needs. The school receives almost all of its funds
from the State, and is heavily regulated. This nexus between the school and the
State is so substantial that the school's action must be considered state action.
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The State and a privately owned enterprise are participants in a joint venture, the
actions of the private enterprise may be attributable to the State.
The State Entanglement Theory - conduct that is formally conducted may be so entwined with
governmental policies or impregnated with governmental character that it can be regarded as
state action.
A Public Function Theory - What matters here is that education is a VITAL public function, not
that it is EXCLUSIVE.
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