Stanley LaFlamme v. Essex Junction School District and Essex Junction Prudential Committee

42 U.S.C. 1983 - Violation of Right to Procedural Due Process - This controversy arose when the Essex Junction Prudential
Committee, which functions as the school board for the Village of
Essex Junction, publicly "censured" LaFlamme, who had been
elected to the Prudential Committee in May 1994. Conflict and
tension between LaFlamme and other committee members plagued his
tenure. For example, members considered LaFlamme difficult to
work with and disruptive of committee proceedings. The committee
particularly took umbrage at LaFlamme's participation in a May
1995 meeting of the Village of Essex Junction Board of Trustees,
at which the formation of a union high school was discussed.
During the meeting, LaFlamme offered opinions that, in the Prudential
Committee's view, were inaccurate, offensive, and belied its
position.

In February 1995, the Chair of the Prudential Committee, Leslie
Mooney, sought advice concerning the committee's working
relationship with LaFlamme from the Executive Director of the
Vermont School Board Association. According to Mooney, the
committee considered the possibility of censuring LaFlamme
because the members had been unsuccessful in their several
attempts to discuss with him issues concerning his committee
membership.

The committee held a special meeting on May 30, 1995, which
LaFlamme did not attend. While in executive session, the members
discussed the ramifications of censure. They agreed to publicly
censure LaFlamme during the next regularly scheduled meeting,
subject to the approval of the committee's legal counsel.

On July 21, 1995, LaFlamme sued defendants and the members of
the Prudential Committee individually. The superior court
dismissed the suit against the individuals on the basis of
immunity afforded to municipal officers under
24 V.S.A. § 901(a). While this lawsuit was pending, LaFlamme served on the
Prudential Committee a second year before resigning. During that
year he made an unsuccessful bid for election to the Village
Trustees.

LaFlamme raised three claims: (1) failure to accommodate
handicap under 9 V.S.A. § 4502, (2) denial of the right to
free speech, and (3) denial of the right to procedural due
process. He withdrew a fourth claim alleging defamation.

The jury found in favor of the defendants on the free speech and handicap claims, but awarded LaFlamme $75,000 in compensatory damages and $25,000 in punitive damages for violation of his right to procedural due process. In essence, the claim upon which the verdict was rendered, as evidenced by the jury instructions, was that the Prudential Committee damaged LaFlamme's reputation so severely

Unknown

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Reversed by the Supreme Court of Vermont. See: __ Vt. ___ (1-21-2000), ___ A.2d ___. Note: The above date reflects the appellate court decision date, not the original trial date. Reported by kkm.