Fields v. City of Tulsa, et al

Plaintiff-appellant Captain Paul Fields of the Tulsa, Oklahoma police department filed a civil rights complaint under 42 U.S.C. 1983 against defendants the City of Tulsa; Charles Jordan, the Chief of Police; and Alvin Daryl Webster, the Deputy Chief of Police. The suit challenged his punishment for objecting to an order requiring him either to attend or to order subordinates to attend a law-enforcement appreciation event hosted by the Islamic Society of Tulsa. He claimed that the punishment violated the First Amendment prohibitions against impairing the rights of free exercise of religion and of association as well as the prohibition against the establishment of religion. He also raised an equal-protection claim. He later sought to amend his complaint to add a claim that his freedom of speech was violated when he suffered retaliation for bringing this lawsuit and a claim that he was denied rights protected by the Oklahoma Religious Freedom Act (ORFA). The district court denied leave to amend and ultimately granted summary judgment for Defendants. Finding no reversible error, the Tenth Circuit affirmed: (1) the Attendance Order did not burden Fields’s religious rights because it did not require him to violate his personal religious beliefs by attending the event; (2) the order did not violate the Establishment Clause because "no informed, reasonable observer would have perceived the order or the event as a government endorsement of Islam;" (3) the Order did not burden Fields’s right of association because it did not interfere with his right to decide what organizations to join as a member; (4) Fields’s equal-protection claim duplicated his free-exercise claim and failed for the same reason; and (5) the district court did not abuse its discretion in denying Fields’s motion to amend the complaint to add ORFA and free-speech retaliation claims because the amendment would have been futile. View "Fields v. City of Tulsa, et al" on Justia Law