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Patronage practice falls squarely within the prohibitions of U.S. Const. amends. I, XIV. Under that practice, public employees hold their jobs on the condition that they provide, in some acceptable manner, support for the favored political party. The threat of dismissal for failure to provide that support unquestionably inhibits protected belief and association, and dismissal for failure to provide support only penalizes its exercise. The belief and association which government may not ordain directly are achieved by indirection. Regardless of how evenhandedly these restraints may operate in the long run, after political office has changed hands several times, protected interests are still infringed and thus the violation remains.
Respondents, non-civil-service employees of the Sheriff's Office of Cook County, Illinois, who were Republicans and who were discharged or threatened with discharge when a Democrat was elected Sheriff to replace a Republican Sheriff, instituted an action in the United States District Court for the Northern District of Illinois against various officials and county Democratic organizations (collectively, “petitioners”), alleging that the respondents had been discharged or threatened with discharge solely because they were not affiliated with or sponsored by the Democratic Party, in violation of the First and Fourteenth Amendments and federal civil rights statutes. The District Court denied a preliminary injunction because of the respondents' failure to show irreparable injury, and ultimately dismissed the complaint for failure to state a claim upon which relief could be granted. The United States Court of Appeals for the Seventh Circuit reversed and remanded, holding that the complaint stated a legally cognizable claim and instructing the District Court to enter appropriate preliminary injunctive relief.
By discharging or threatening to discharge respondents under the circumstances, did petitioners violate respondents’ First and Fourteenth Amendment rights?
The Court affirmed the reversal of a judgment dismissing respondent county employees' complaint alleging that political patronage dismissals violated U.S. Const. amends. I, XIV and granting a preliminary injunction. It held that patronage dismissals severely restricted political belief and association, were unconstitutional under the First and Fourteenth Amendments, and that respondents stated a valid claim for relief. Though there was a need for government efficiency and effectiveness, such dismissals were not the least restrictive means for fostering that end. There was also a need to insure that policies which the electorate had sanctioned were effectively implemented, but that interest could be fully satisfied by limiting patronage dismissals to policymaking positions. Finally, patronage dismissals could not be justified by their contribution to the proper functioning of the democratic process through their assistance to partisan politics since political parties were nurtured by other, less intrusive, and equally effective methods. Any contribution of patronage dismissals to the democratic process did not override their encroachment on First Amendment freedoms.