In a 42 U.S.C. section 1983 action alleging that defendant-hospital board deprived plaintiff-physician of his First Amendment right of free speech through a campaign of retaliation against him for speaking out about substance abuse at the hospital, summary judgment for defendants is affirmed where neither the hospital's investigation of plaintiff nor its warning letter to him constituted an adverse employment action for First Amendment purposes.
Filed November 17, 2009
Opinion by Judge Ebel
Janet Schroer, Monty Barnett, John Lebsack and James M. Meseck, White and Steele, P.C., Denver, CO