Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 1 of 16

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
KELVIN J. COCHRAN,

Plaintiff,
v.
CITY OF ATLANTA, GEORGIA;
and MAYOR KASIM REED, in his
individual capacity.
Defendants.

CASE NO.
1:15-cv-00477-LMM

CITY DEFENDANTS REPLY BRIEF

IN SUPPORT OF THEIR MOTION TO DISMISS
Defendants City of Atlanta, Georgia and Mayor Kasim Reed (City
Defendants) hereby file this Reply Brief in Support of Their Motion to Dismiss.
I. ARGUMENT AND CITATIONS TO AUTHORITY
A. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
ONE OF HIS COMPLAINT, FIRST AMENDMENT RIGHT TO
FREEDOM OF SPEECH: RETALIATION (42 U.S.C. 1983).
1. Plaintiffs speech was not as a private citizen on a matter
of public concern.
If the government employee speaks not as a citizen upon matters of public
concern, but instead as an employee upon matters only of personal interest, absent
the most unusual circumstances, a federal court is not the appropriate forum in which
to review the wisdom of a personnel decision taken by a public agency allegedly in
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reaction to the employee's behavior.1 Moreover,

because [a]n employee's speech will rarely be entirely private or
entirely public, the main thrust of the employee's speech must be
determined. 6 F.3d at 755. This determination is made by examining
the content, form, and context of a given statement, as revealed by the
whole record. Connick, 461 U.S. at 14748, 103 S.Ct. at 1690;
Morgan, 6 F.3d at 754.2
In making this determination, the mere fact that the topic of the employee's speech
was one in which the public might or would have had a great interest is of little
moment.3
In the instant case, Plaintiff alleges that he wrote a Bible study for his church
group which he eventually self-published as a book of spiritual guidance for
Christian men.4 Although the book has garnered public attention since it came to
light that Plaintiff violated the Citys Ethics Code by failing to obtain written prior
approval from the Board of Ethics, the original intent of the speechbased on the
facts Plaintiff alleges in his Complaintwas to create a very specific guidebook as
a resource for a very specific audience.5 Rather than appealing to the general public
as an expression of or introduction to Plaintiffs religious beliefs, Plaintiff alleges

Maggio v. Sipple, 211 F.3d 1346, 1352 (11th Cir. 2000) (quoting Connick v. Myers,
461 U.S. 138, 147, 103 S.Ct. 1684, 1690 (1983)).
2
Maggio, supra, at 1352.
3
Morgan v. Ford, 6 F3d 750, 754 (11th Cir. 1993) (quoting Kurtz, 855 F.2d at 727
(internal citations omitted)).
4
Doc. 1, 83-89, 91-93.
5
Doc. 1, 94.
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this book was written for members of his religious faith who already shared his
beliefs but were struggling with the full application of those beliefs to their daily
lives.6

Plaintiff further alleges that he primarily distributed the book to his

subordinates at AFRD who asked for the book or whom he knew to be Christian.7
Although Plaintiff argues that there is a national debate over same-sex marriage and
that Plaintiffs book makes an important contribution to this debate8, Plaintiffs
Complaint states that the book contains just a few passages concerning sexual
morality,9 that only 6 pages of the 162-page long book address Biblical standards of
sexual morality10, and that [t]he rest of the book deals with Christian teaching
concerning original sin and the ability of Christians to overcome the influence of sin
in their lives through fully embracing and understanding the sacrifice of Jesus
Christ.11 This description does not support a finding that the publication and
distribution of Plaintiffs book at the workplace was intended to relate to a matter of
public concern.
Plaintiff contends that public concern is an extremely broad concept that
includes almost any matter other than speech that relates to internal struggles within

Doc. 1, 93-94.
Doc. 1, 127-128 and 130-131.
8
Doc. 15, p. 12.
9
Doc. 1, 8.
10
Doc. 1, 102-103.
11
Doc. 1, 104.
7

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the workplace.12 However, Plaintiff supports this contention with cases from
outside of this Circuit13 that are not controlling. Plaintiff also relies upon U.S. v.
Natl Treasury Employees Union, 513 U.S. 454, 466 (1995) for the proposition that
government employers cannot prohibit employees from speaking publicly for
compensation. However, U.S. v. Natl Treasury is inapt to the facts in the instant
case. The Supreme Court in U.S. v. Natl Treasury examined Section 501(b) of the
Ethics in Government Act of 1978 and determined that a blanket prohibition on
certain government employees receipt of honoraria in exchange for making an
appearance, speaking, or writing an article violated the First Amendment. The
Supreme Court reasoned that
[t]he sweep of 501(b) makes the Government's burden heavy. Unlike
Pickering and its progeny, this case does not involve a post hoc analysis
of one employee's speech and its impact on that employee's public
responsibilities. Cf. Waters v. Churchill, 511 U.S. 661, 114 S.Ct. 1878,
128 L.Ed.2d 686 (1994); Rankin v. McPherson, 483 U.S. 378, 107 S.Ct.
2891, 97 L.Ed.2d 315 (1987); Connick v. Myers, 461 U.S. 138, 103
S.Ct. 1684, 75 L.Ed.2d 708 (1983); Perry v. Sindermann, 408 U.S. 593,
92 S.Ct. 2694, 33 L.Ed.2d 570 (1972). Rather, the Government asks us
to apply Pickering to Congress' wholesale deterrent to a broad category
of expression by a massive number of potential speakers. In Civil
Service Comm'n v. Letter Carriers, 413 U.S. 548, 564, 93 S.Ct. 2880,
2890, 37 L.Ed.2d 796 (1973), we established that the Government must
be able to satisfy a balancing test of the Pickering form to maintain a
statutory restriction on employee speech. Because the discussion in that
12

Doc. 15, p. 10 (quoting Tucker v. State of Cal. Dept. of Educ., 97 F3d 1204,
1210 (9th Cir. 1996)).
13
Tucker, supra, (in which a State of California agency imposed a flat ban on
religious speech and expression) and Scarbrough v. Morgan Cnty. Bd. of Educ., 470
F.3d 250, 257 (6th Cir. 2006).
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case essentially restated in balancing terms our approval of the Hatch

Act in Public Workers v. Mitchell, 330 U.S. 75, 67 S.Ct. 556, 91 L.Ed.
754 (1947), we did not determine how the components of the Pickering
balance should be analyzed in the context of a sweeping statutory
impediment to speech.14
The nature and scope of 501(b) as examined in U.S. v. Natl Treasury, supra, is
not analogous to the City Ordinance at issue in this case15 which requires that
department heads obtain written pre-approval of outside employment by the Board
of Ethics and does not constitute a blanket prohibition of speech or writing for
compensation.
2. Plaintiffs interest in publishing his book without
complying with a work rule requiring prior written
approval and distributing his book to subordinates in the
workplace is not a constitutionally guaranteed right, and
is outweighed by the City Defendants interest as a
governmental employer in the efficient operation of a
paramilitary division such as the Atlanta Fire Rescue
Department.
Even if an employee does speak as a citizen on a matter of public concern,
the employee's speech is not automatically privileged. Courts balance the First
Amendment interest of the employee against the interest of the State, as an
employer, in promoting the efficiency of the public services it performs through its

14
15

U.S. v. Natl Treasury

City of Atlanta Code of Ordinances Sec. 2-820(d), Doc. 1, 171.
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Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 6 of 16

employees.16
Plaintiff contends that he has not only an equal right, but a superior right, to
express his religious beliefs.17 However, Plaintiffs Complaint shows that his long
held beliefs never posed an issue with his employment until his publication, sale,
and distribution of a book in the workplace for which he admittedly did not obtain
pre-approval pursuant to a work rule codified in the City Code of Ethics came to the
attention of the City Council.18 Thus, Plaintiffs religious beliefs were a non-issue
for the greater part of his employment with the City until they happened to intersect
with personnel issues.
Once the work rule violation came to light, the City had an interest, as set
forth in Defendants brief in support of their Motion to Dismiss, to maintain the
orderly operation and esprit de corp of the AFRD, which isin addition to being a
division of a governmental employera paramilitary organization with heightened
need to maintain public confidence, order, and discipline.19
The key to First Amendment analysis of government employment
decisions, then, is this: The government's interest in achieving its goals
as effectively and efficiently as possible is elevated from a relatively
subordinate interest when it acts as sovereign to a significant one when
it acts as employer. The government cannot restrict the speech of the
16

Borough of Duryea, Pa. v. Guarnieri, 131 S. Ct. 2488, 2493 (2011) (quoting
Pickering v. Board of Ed. of Township High School Dist. 205, Will Cty., 391 U.S.
563, 568, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968)).
17
Doc. 15, pp. 14-15.
18
Doc. 1, 1, 2, 5-8.
19
See Anderson v. Burke County, Ga., 239 F.3d 1216 (11th Cir. 2001).
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Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 7 of 16

public at large just in the name of efficiency. But where the government
is employing someone for the very purpose of effectively achieving its
goals, such restrictions may well be appropriate.20
Furthermore,
a citizen who accepts public employment must accept certain
limitations on his or her freedom. Garcetti v. Ceballos, 547 U.S. 410,
418, 126 S.Ct. 1951, 164 L.Ed.2d 689 (2006). The government has a
substantial interest in ensuring that all of its operations are efficient and
effective. That interest may require broad authority to supervise the
conduct of public employees. Restraints are justified by the
consensual nature of the employment relationship and by the unique
nature of the government's interest.21
Plaintiffs assertion that Defendants have failed to show any disruptions to
AFRD operations is irrelevant to this analysis. A public employer need not wait for
a disruption or disturbance to occur before taking action.22
B. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR AND
LACKS STANDING TO ASSERT COUNT TWO OF HIS
COMPLAINT, FIRST AMENDMENT RIGHT TO FREEDOM OF
SPEECH: VIEWPOINT DISCRIMINATION, OVERBREADTH,
PRIOR RESTRAINT AND UNBRIDLED DISCRETION (42 U.S.C.
1983).
Plaintiff contends that he has standing to bring Count Two of his Complaint
because he was terminated for failure to comply with City Code Sec. 2-820(d).23
However, the Eleventh Circuit Court of Appeals in CAMP Legal Defense Fund, Inc.

20

Waters v. Churchill, 511 U.S. 661, 674-675, 114 S.Ct. 1878, 1887-1888, 128
L.Ed.2d 686 (1994) (citations omitted).
21
Borough of Duryea, Pa, supra, at 2494.
22
See Connick, supra.
23
Doc. 15, pp. 19-22.
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Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 8 of 16

v. City of Atlanta 24 found that

CAMP lacks standing to challenge two of the five provisions as prior
restraints. CAMP failed to present evidence that it has, or imminently
will be, denied a permit for failure to pay fees or perform a cleanup
plan. See id. 138207(b)(7), (8). CAMP also presented no evidence,
by affidavit or other evidence, that these provisions apply to the
permits it seeks. See Lujan, 504 U.S. at 560, 112 S.Ct. at 2136. Because
the record does not evidence an actual or imminent injury from these
provisions, CAMP lacks standing to challenge them, and we lack
jurisdiction to consider them.25
Here, Plaintiff has not alleged that he was denied pre-approval to publish and sell
his book, and cannot show the injury in fact required to establish standing to bring
Count Two of his Complaint.
C. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
THREE OF HIS COMPLAINT, FIRST AMENDMENT RIGHT TO
THE FREE EXERCISE OF RELIGION AND NO RELIGIOUS
TESTS CLAUSE OF ART. VI, 3 OF THE CONSTITUTION (42
U.S.C. 1983).
As Defendants asserted in their Motion to Dismiss, the Eleventh Circuit Court
of Appeals found in Watts, supra, that [a]pplying the teachings of Twombly and our
decisions to the pleading issue in this case, the question [on a motion to dismiss
amended complaint] is whether Watts has alleged enough facts to suggest, raise a
reasonable expectation of, and render plausible the fact that he sincerely held the
religious belief that got him fired.26 Applying the holding of Thomas, [a plaintiff

24

CAMP Legal Defense Fund, Inc. v. City of Atlanta, 451 F.3d 1257 (11th Cir. 2006)
25
Id. at 1269.
26
Id. at 1296.
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to survive a motion to dismiss] must plead that he believes his religion compels him
to take the actions that resulted in his termination.27 Plaintiffs response on this
Count fails to address how his sincerely held religious belief compelled him to
publish a book without pre-approval and distribute it in the workplace, which lead
to his termination.
D. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
FOUR OF HIS COMPLAINT, FIRST AMENDMENT RIGHT TO
FREE ASSOCIATION (42 U.S.C. 1983).
Plaintiff fails to state a claim for Count Four for the reasons set forth in
Defendants Motion to Dismiss.

Plaintiff argues that the right of expressive

association is distinct from the right of intimate association. However, these two
closely related rights are given similar special protection under the law of this
Circuit, and, therefore, are analyzed in similar fashion.28.
E. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
FIVE OF HIS COMPLAINT, FIRST AMENDMENT RIGHT TO
AVOID RELIGIOUS HOSTILITY: ESTABLISHMENT (42 U.S.C.
1983).
The Supreme Court has explained that the purpose of the Establishment and
Free Exercise Clauses of the First Amendment is to prevent, as far as possible, the

27

Id. at 1297.
See McCabe v. Sharrett, 12 F.3d 1558, 156263 (11th Cir.1994), Roberts v.
United States Jaycees, 468 U.S. 609, 61718, 104 S.Ct. 3244, 324950, 82
L.Ed.2d 462 (1984); City of Dallas v. Stanglin, 490 U.S. 19, 2325, 109 S.Ct.
1591, 159495, 104 L.Ed.2d 18 (1989); Cummings v. DeKalb County, 424 F.3d
1349 (11th Cir. 1994).
28

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intrusion of either [the church or the state] into the precincts of the other.29 To
determine whether there has been a violation of the Establishment Clause, [r]ather
than mechanically invalidating all governmental conduct or statutes that confer
benefits or give special recognition to religion in general or to one faiththe Court
has scrutinized challenged legislation or official conduct to determine whether, in
reality, it establishes a religion or religious faith, or tends to do so.30
Plaintiff contends that his claim is based on hostility toward his religious
beliefs by favoring and establishing other religions.31 While the Complaint alleges
a difference in viewpoints between the Plaintiff and Defendants, nowhere does it
allege that viewpoints in favor of same-sex marriage and homosexual conduct32 is
an alternate religious viewpoint that is being favored or established by the
Defendants.
F. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT SIX
OF HIS COMPLAINT, FOURTEENTH AMENDMENT RIGHT TO
EQUAL PROTECTION OF THE LAWS (42 U.S.C. 1983).
Plaintiff has failed to articulate a claim for violation of his right to equal
protection under the Fourteenth Amendment for the reasons set forth in Defendants

29

Lynch v. Donnelly, 465 U.S. 668, 104 S.Ct. 1355, 1358--1359 (1984) (quoting
Lemon v. Kurtzman, 403 U.S. 602, 614, 91 S.Ct. 2105, 2112, 29 L.Ed.2d 745
(1971)).
30
Id. at 1361-1362 (citing Walz v. Tax Commission of City of New York, 397 U.S.
664, 668-669, 90 S.Ct. 1409, 1411, 25 L.Ed.2d 697 (1970)).
31
Doc. 15, pp. 26-27.
32
Doc. 15, p. 27.
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Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 11 of 16

Motion to Dismiss. Furthermore, Plaintiffs contention that he was terminated for

being part of a class consisting of all Christian members of a Christian church33 is
not supported by the facts alleged in his Complaint, which does not allege that
Christian City employees who are church members are denied equal protection.
Rather, as discussed supra, the allegations in the Complaint show that Plaintiffs
Christian faith and affiliation with a Christian church were non-issues relative to his
City employment until he violated a work rule applicable to all department heads
engaging in outside employment.
G. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
SEVEN OF HIS COMPLAINT, FOURTEENTH AMENDMENT
RIGHT TO DUE PROCESS: VAGUENESS (42 U.S.C. 1983).
Plaintiff contends that the requirement for department heads to obtain preapproval in writing from the board of ethics prior to engaging in outside employment
for remuneration is unconstitutionally vague. However, Plaintiff fails to address
Theater v. Palm Beach County Sheriffs Office, 449 F.3d 1342 (11th Cir. 2006), a
case that examines an almost identical work rule in a paramilitary organization
setting. The Court in Theater found that, [s]ignificantly, the rule requiring prior
written approval before engaging in off-duty employment is not obtuse or
ambiguous.34 The cases Plaintiff cites in response to Defendants Motion to Dismiss

33

Doc. 15, p. 27-28.

Id. at 1355-1356 (citing Colten v. Kentucky, 407 U.S. 104, 110, 92 S.Ct. 1953,
1957, 32 L.Ed.2d 584 (1972) (explaining that a rule should comport with a rough

34

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are not in the context of a work rule applied to government employees in a

paramilitary organization, and thus, are not analogous to the instant case.
H. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
EIGHT OF HIS COMPLAINT, FOURTEENTH AMENDMENT
RIGHT TO DUE PROCESS: LIBERTY INTEREST (42 U.S.C.
1983).
Plaintiff has not demonstrated that he had a property interest in his
employment. As stated in Defendants Motion to Dismiss, Plaintiff was as an
appointed head of a City Department who was an unclassified employee without
property interest or appeal rights attendant to his at-will employment.35 None of the

idea of fairness .... and [be] sufficiently specific to provide fair warning that certain
kinds of conduct are prohibited). The rule is easily understood by persons of
ordinary intelligence. Zook v. Brown, 865 F.2d 887, 892 (7th Cir. 1989) (concerning
failure of deputy sheriff to obtain prepublication review from the sheriff before
submitting a letter for publication in a local newspaper); see Connally v. General
Constr. Co., 269 U.S. 385, 391, 46 S.Ct. 126, 127, 70 L.Ed. 322 (1926) (determining
that a regulation is facially vague when it either forbids or requires the doing of an
act in terms so vague that men of common intelligence must necessarily guess at its
meaning and differ as to its application)) (emphasis added).
35
Pursuant to F.R.E. Rule 201(b), the Court may take judicial notice of City of
Atlanta Code of Ordinances Sec. 3-501(a) re: division of City employment into a
system of classified and unclassified service, Sec. 114-84(b)(7) re: department heads
being unclassified employees, Sec. 114-546(1) re: limitation of appeal rights to
classified employees, Sec. 114-78 re: application of the progressive discipline and
appeal code sections to classified employees, and City of Atlanta Communication
10-C-1361 appointing Kelvin Cochran to serve as Chief of Atlanta Fire and Rescue
without conferring classified status or other property interest in his employment.
(See Municode.com (Code Library, Georgia, Atlanta) and Doc. 1, 171 for City of
Atlanta
Code
of
Ordinances
Sections
cited
above,
and
http://citycouncil.atlantaga.gov/2010/images/adopted/0816/10C1361.pdf for City of
Atlanta Communication 10-C-1361).
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paragraphs of the Complaint that Plaintiff cites as statements that false and
stigmatizing allegations were made against Plaintiff actually show any such
allegation. Furthermore, Plaintiffs reliance on Thomas v. Harvard36 is misplaced
as statements in this case regarding Plaintiffs failure to follow work rules do not
equate to allegations of criminal conduct in Thomas. Count Eight of Plaintiffs
Complaint should be dismissed for failure to state a claim.
I. PLAINTIFF FAILS TO SET FORTH A CLAIM FOR COUNT
NINE OF HIS COMPLAINT, FOURTEENTH AMENDMENT
RIGHT TO DUE PROCESS: PROCEDURE (42 U.S.C. 1983).
As discussed in Defendants Motion to Dismiss, Plaintiff was an at will public
employee with no property interest in his job and no due process rights. Plaintiff
relies on City Code Sec. 114-528 and Cleveland Bd. of Educ. v. Loudermilk37 in
support of his contention that Plaintiff had a property interest in his employment
with the City. Both Section 114-538 and Cleveland Bd. of Educ. involve due process
rights conferred upon certain classes of employees legislatively. As discussed in
Defendants Motion to Dismiss, page 21, note 45, City Code Sec. 114-528 only
applies to City employees in the classified service, which Plaintiff as a department
head is not. Therefore, Plaintiff is not entitled to due process pursuant to City of
Atlanta Code of Ordinances 114-528, or under any other authority, and Count Nine

36
37

45 F.Supp.2d 1353 (N.D.Ga. 1999).

470 U.S. 532 (1985).
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of his Complaint should be dismissed.

II.

CONCLUSION
Although Plaintiff contends his claims in this lawsuit are Constitutional

issues, the facts alleged in his Complaint reveal what is essentially a personnel
matter involving Plaintiffs termination from an executive level, at-will position for
failure to follow a codified work rule that required pre-approval of outside paying
jobs for City department heads. Plaintiff should not be permitted to use his religious
affiliations and beliefs to circumvent personnel decisions the City as a governmental
employer operating a paramilitary department has the lawful discretion to make in
order to provide efficient services to the public.
Therefore, based on the foregoing and on the arguments and authorities
previously set forth in Defendants Brief in Support of Motion to Dismiss, the
Defendants respectfully submit that this Court should grant Defendants Motion to
Dismiss on all Counts of the Plaintiffs complaint.
TYPESET CERTIFICATION
I hereby certify pursuant to Local Rules 5.1(b) and 7.1(d) that I prepared this
document in Times New Roman 14-point font.
Respectfully submitted, this 22nd day of April, 2015.

[signatures on following page]

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Case 1:15-cv-00477-LMM Document 19 Filed 04/22/15 Page 15 of 16

Robert N. Godfrey
Chief Counsel
Georgia Bar No. 298550
/s/Y. Soo Jo
Y. Soo Jo
Sr. Assistant City Attorney
Georgia Bar No. 385817
Attorneys for Defendants

CITY OF ATLANTA LAW DEPARTMENT

55 Trinity Ave., S.W., Suite 5000
Atlanta, Georgia 30303
404-546-4151 (Direct telephone)
404-739-4888 (Facsimile)
ysjo@atlantaga.gov

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

KELVIN J. COCHRAN,

Plaintiff,
v.
CITY OF ATLANTA, GEORGIA;
and MAYOR KASIM REED, in his
individual capacity.
Defendants.

CASE NO.
1:15-cv-00477-LMM

CERTIFICATE OF FILING AND SERVICE

I hereby certify that on April 22, 2015, I electronically filed a copy of
DEFENDANTS REPLY BRIEF IN SUPPORT OF THEIR MOTION TO
DISMISS with the Clerk of Court using the CM/ECF system which will
automatically send notification of such filing to all counsel of record.

/s/ Y. Soo Jo
Y. SOO JO

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