Sanguigni v. Pittsburgh Board of Public Education

Phyllis J. Sanguigni, a public high school teacher, filed this action against the school board and various school officials, alleging that she had lost her coaching positions and had been penalized in other ways for publishing certain statements in a faculty newsletter. She asserted First Amendment and due process claims, as well as pendent state claims. The district court dismissed her complaint for failure to state a claim. We hold that the statements in question do not pertain to matters of "public concern" under Connick v. Myers, 461 U.S. 138, 75 L. Ed. 2d 708, 103 S. Ct. 1684 (1983), and related cases and that Sanguigni did not adequately allege that she had a property interest in her coaching positions. We therefore affirm.