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Steigmann v. Democratic Party of Illinois

December 20, 2005


The opinion of the court was delivered by: Amy J. St. Eve, District Court Judge


Plaintiff Richard D. Steigmann filed suit against the Democratic Party of Illinois, Governor Rod R. Blagojevich, Joseph Handley, Randal E. Thomas, and John G. Sheedy, alleging that Defendants are liable under 42 U.S.C. § 1983 for retaliatory discharge (and conspiracy to accomplish the same) in violation of the First and Fourteenth Amendments to the United States Constitution. In short, this case, like many that are currently pending, "deals with the long-running saga of political patronage hiring and firing in Illinois." Thompson v. Illinois Dept. of Prof. Reg., 300 F.3d 750, 751-52 (7th Cir. 2002). Currently before the Court, are the Defendants' motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). For the following reasons, the Court grants Defendants' motions.


The Complaint alleges the following facts:

I. The Parties

Plaintiff Richard D. Steigmann ("Steigmann" or "Plaintiff") is an Illinois resident (R. 35-1, Am. Compl. at ¶2) who claims to be a "well-known, active, and prominent" member of the Republican Party. (Id. at ¶10.) Steigmann is an elected City of Champaign Precinct Committeeman of the Republican Party of Illinois. (Id. at ¶9.) Steigmann also serves as the Champaign County Republican Party District Coordinator for Champaign County District 4 and is responsible for the direction of the political activity of the Republican Precinct Committeemen and their required attendance at all Republican Party functions. (Id. at ¶11.) In 1999 and 2000, Steigmann served as a Republican member of the Champaign County Board, representing a City of Champaign District. (Id. at ¶12.) Steigmann's political activities on behalf of the Republican Party included serving as Campaign Manager for Jerry Schweighart, as Campaign Manager in 1999-2000 for Circuit Court Judge Michael Q. Jones, and as Campaign Coordinator in 1999-2000 for Congressman Tim Johnson. (Id. at ¶13.) In addition, Steigmann's brother, the Honorable Robert J. Steigmann, is a judge affiliated with the Republican Party (and successfully ran under its banner in 1994) who currently sits on the Fourth District Appellate Court for the State of Illinois. (Id. at ¶14.)

Defendant Democratic Party of Illinois (the "Democratic Party") is a political organization registered in the state of Illinois. (Id. at ¶3.) Defendant Rod R. Blagojevich ("Governor Blagojevich") is the current governor of Illinois and a member of the Democratic Party. (Id. at ¶4.) Defendant Joseph Handley ("Handley") is the Deputy Chief of Staff to Governor Blagojevich, the "patronage coordinator" between the Democratic Party and Governor Blagojevich, and a member of the Democratic Party. (Id. at ¶5.) Defendant Randal E. Thomas ("Thomas") is the Adjutant General of Illinois and a member of the Democratic Party.*fn1 (Id. at ¶6.) The Adjutant General is a cabinet-level position of the Executive Branch of the Illinois government and is appointed by the governor.*fn2 (Id. at ¶20.) Defendant John G. Sheedy ("Sheedy") is the Director of Special Staff for the Illinois Army and Air National Guard. (Id. at ¶7.)

II. Steigmann's Employment with Lincoln's Challenge Academy

On or about January 3, 2000, Illinois Department of Military Affairs ("IDMA") hired Steigmann to serve as the Community Relations Specialist for Lincoln's Challenge Academy ("LCA"), a quasi-military institution operated as part of the Illinois National Guard. (Id. at ¶¶16, 22.) The IDMA -- an executive branch department within the control of Thomas, as the Adjutant General -- has statutory authority to conduct and administer the affairs of LCA. (Id. at ¶¶18-19.) LCA receives approximately sixty percent of its funding from the federal government.*fn3 (Id. at ¶17.)

The IDMA renewed Plaintiff Steigmann's employment contract on July 1, 2000. (Id. at ¶24; see also id. at ¶21 (alleging that, through Sheedy, Thomas is responsible for the "execution and administration of contracts of employment with teachers and support staff" employed by LCA).) The 2000 contract, which covered the period from July 1, 2000 through June 30, 2002, created Steigmann's Community Relations position at LCA. (Id. at ¶¶25, 26.) The IDMA renewed Steigmann's 2000 contract on July 1, 2002 to last through June 30, 2004. (Id. at ¶¶32, 33.) Steigmann alleges that the IDMA had a "longstanding policy and practice to automatically renew contracts of LCA employees," except when the employee had job performance problems. (Id. at ¶23.)

Steigmann alleges that his Community Relations position at LCA, as specified in his 2000 and 2002 employment contracts, was a "non-policymaking and non-confidential position," since it required him to perform all of his duties "in accordance with LCA policies and goals." (Id. at ¶¶27, 28, 35, 36.) Steigmann did not append the current job description (which was incorporated by reference into the 2002 contract) to his complaint, but Defendants attached it to their motion to dismiss. (R. 46-1, State Officials' Mot. to Dismiss, Ex. B.) That job description identifies the following duties for the Community Relations position:

Under the general supervision of the Director, plans, implements, and supervises programs designed to advance the objectives of the Department and the Lincoln's Challenge Academy and programs that assist cadets.

1. In accordance with LCA policies and goals, develops projects to maintain and advance departmental, programmatic, and governmental community relations. Assembles data and prepares reports regarding cadets and the State and Federal legislative districts from which they originate.

2. Serves as the Academy Grant Writer. Submits official proposals to agencies for solicitation of grants is the point of contact regarding donations and contributions in order to receive matching federal funds. Develops problem solving techniques and researches methods of acquisition in regards to grants, donations, and contributions. Assists as needed in recruitment of mentors from the communities.

3. Works directly with members of the public, civic organizations, and specific community groups on joint projects that serve to enhance the image of the program and advance its objectives. Plans, coordinates, and executes special events that serve to advance community relations; including motivational and keynote speakers, tours of the Academy, press releases and coverage, State Advisory Council Meetings, cadet ceremonies, etc.

4. Provides creative support for departmental and program publications based on guidance from the National Guard Bureau. Coordinates with state headquarters, directorates, brigades, and air bases on joint military projects that enhance staff and community relations.

5. Performs other duties as required or assigned which are reasonably within the scope of duties enumerated above.

(Id., Ex. B.) The State Officials also attached the job description incorporated into the 2000 contract; that description varies somewhat from the current one. (R. 35-1, Am. Compl. at ¶¶34, 35.)*fn4

III. The Alleged Patronage Dismissal

Governor Blagojevich, the candidate for the Democratic Party, was elected governor of Illinois on November 5, 2002. (R. 35-1, Am. Compl. at ¶41.) George Ryan, a member of the Republican Party, previously held the position of governor in Illinois. (Id. at ¶42.) Once elected, Governor Blagojevich instituted Executive Order 1, which stated, "no . . . department . . . subject to the control or direction of the Governor shall take any . . . action which will result in the increase or maintenance of present levels in State employment or compensation . . . payable in connection with State employment, including personal service contracts." (Id. at ¶46.) Steigmann alleges that this Executive Order was instituted pursuant to Governor Blagojevich's "policy to retaliate against and dismiss any employee prominently associated with the Republican Party." (Id. at ¶45.)

In order to further this objective, Steigmann alleges that Governor Blagojevich designated Handley as deputy Chief of Staff to coordinate patronage employment decisions for the Democratic Party. (Id. at ¶48.) Steigmann claims that Governor Blagojevich, the Democratic Party, Handley, and Thomas targeted for removal employees prominently associated with the Republican Party and specifically Steigmann "for his associational activities and blood relation to Justice Robert J. Steigmann." (Id. at ¶52.) Steigmann also alleges that Governor Blagojevich, through Handley, delegated the "hiring and firing authority" with respect to Steigmann's position to the Democratic Party. (Id. at ¶55.) In particular, Steigmann alleges that Governor Blagojevich, Handley, and the Democratic Party: (1) entered an agreement to use the hiring and firing process at LCA to directly harm and harass Steigmann for his personal and political associations (id. at ¶56); (2) departed from LCA's longstanding policy, by soliciting applicants for LCA positions, even if those positions already were occupied (id. at ¶57); (3) solicited only those applicants who were members or actively involved in the affairs of the Democratic Party (id at ¶¶58-60); and (4) did not permit then-current LCA employees to apply for a promotion (id. at ¶61).

On or about June 30, 2004, Steigmann claims that Thomas directed Sheedy not to renew Steigmann's employment contract. (Id. at ¶63.) As a result, Steigmann was terminated as LCA's Community Relations Specialist on June 30, 2004. (Id. at ¶62.) Plaintiff did not receive any explanation for the decision not to renew his contract. (Id. at ¶64.) On July 1, 2004, the Defendants replaced Steigmann with Charles "Chub" Connor, a former elected official affiliated with the Democratic Party and a prominent and active member of that organization. (Id. at ¶¶65-66.)

Steigmann contends that his termination is actionable under 42 U.S.C. § 1983 because it violated the First and Fourteenth Amendments to the United States Constitution.


I. Legal ...

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