Keefe v. Adams

Craig Keefe (plaintiff), a nursing student, posted unprofessional comments on Facebook about fellow students, including a statement about wanting to use "this electric pencil sharpener" to give someone a hemopneumothorax. Two classmates complained, one saying she no longer felt comfortable working with Keefe. His instructor forwarded the posts to the nursing director, who met with Keefe (who claimed his account was hacked and it was mostly jokes) and ultimately decided she could not teach him the professionalism required under the Nurses Association Code of Ethics, a required part of the curriculum, and dismissed him effective end of semester. After an unsuccessful internal appeal, Keefe sued several Central Lakes College administrators (defendants), arguing his First Amendment and due-process rights were violated since the speech occurred entirely off campus and unrelated to any class. The trial court granted summary judgment for the administrators, and Keefe appealed.