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Tuesday, November 25, 2025

INDIVIDUAL RIGHTS—7th Cir.: Deputy warden, fired for posting offensive memes on Facebook, cannot revive claims - VitalLaw.com

The posts, only viewable by his 1,200 Facebook “friends,” were disparaging towards Muslims, Black people, liberals, and the LGBTQ community, and one referred to the Confederate flag as “our flag.”

Affirming a district court’s grant of summary judgment against the First and Fourteenth Amendment claims brought by the former deputy warden for the Wisconsin Correctional Center System (WCCS), the Seventh Circuit determined that the WCCS’s interests as a public employer—particularly its duty to maintain security and discipline in correctional facilities—outweighed the deputy warden’s interest in posting this type of material on Facebook. With regard to the deputy warden’s due process claim, he had argued the WCCS failed to give notice to employees that social-media posts might jeopardize their jobs. However, the court found that public employers are not constitutionally required to adopt specific policies before disciplining employees for activities that may interfere with their job duties (Schneiter v. Carr, No. 22-2137 (7th Cir. July 31, 2025)).

Hired as an entry-level correctional officer in 1977, the plaintiff gradually moved up the career ladder and in 2011 was promoted to the significant leadership position of deputy warden for the Wisconsin Correctional Center System. The WCCS encompasses a network of 14 minimum-security prisons scattered throughout the state.

Facebook posts. Over the course of several weeks in June 2019, the deputy warden posted on his Facebook page...



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