Rendell-Baker v. Kohn

Kohn (defendant) directed New Perspectives School, a private nonprofit school for "at-risk" students that received nearly all its funding from public school districts and the government and was subject to Massachusetts regulations. Rendell-Baker (plaintiff), a school counselor, was fired after a dispute over a student-staff council's role in hiring decisions; five teachers who protested her firing by writing letters demanding Kohn's resignation and picketing were fired the next day. Rendell-Baker and the teachers sued under 42 U.S.C. § 1983, claiming Kohn violated their First Amendment rights and due process by firing them without state-actor-level protections. The district court dismissed Rendell-Baker's claim but let the teachers' claim proceed; the court of appeals reversed, finding no state action, and the Supreme Court granted certiorari.