Parents who criticize or trash talk their kids’ public high school coaches don’t have legal protection to make false claims, according to a groundbreaking ruling issued Wednesday by the Minnesota Supreme Court.
The court’s decision, in a case involving former Woodbury High School girls’ basketball coach Nathan McGuire, said that public high school coaches are not public officials under the First Amendment. That means that such coaches who claim to have been defamed by parents have a lower bar to clear to prove their case.
McGuire’s attorney, Donald Chance Mark Jr., said the decision will matter throughout the state because it “finally provides an opportunity for coaches to defend their reputations when [parents] say things that are either untrue or, in some cases, lies.”
Public high school coaches aren’t public officials under the law, according to the court, because their decisions about playing time and benching tardy players aren’t core government functions.
The 16-page unanimous decision, written by Justice Natalie Hudson, is the first time that Minnesota’s highest court has ruled on the issue.
“Simply, basketball is not fundamental to democracy,” the ruling said.
High courts in five other states have decided the issue, with four of them also saying that public high school coaches don’t qualify as public officials. Raleigh Levine, a professor at Mitchell Hamline School of Law and a First Amendment expert, said the U.S. Supreme Court has not ruled on whether public school teachers or coaches are public officials.
Both the Minnesota State High School Coaches Association and the National High School Basketball Coaches Association filed briefs with the state Supreme Court in support of McGuire, a kindergarten teacher as well as coach.
The decision reinstates McGuire’s defamation case against Julie Bowlin, one of the parents who criticized him while he was coach at Woodbury from fall 2012 until March 2014, when district officials decided not to renew his contract.
Bowlin and two other parents had told school administrators that McGuire gave one player a back rub during an away game and moved other players around by their shoulders and hips at practice, the court said. Another parent, Chelon Danielson, also wrote a letter to the administrators complaining about McGuire.
Bowlin and Danielson filed “maltreatment-of-minor” complaints with the state Department of Education. The agency investigated and determined that Bowlin’s daughter wasn’t mistreated. The court also said there was no evidence suggesting Danielson’s daughter had been mistreated.
After McGuire was dismissed from his coaching job, Bowlin continued to criticize him. She told one parent in August 2014 that McGuire “was recently put in jail,” and a few months later told another that he had been involved in stealing funds.
McGuire filed a lawsuit against Bowlin and Danielson in December 2015, claiming they had defamed him and filed false maltreatment claims with the state. The district court dismissed his case on grounds that, as a public high school coach, he was a public official and had failed to prove the parents had “knowingly or recklessly” made a false report.
The state Court of Appeals upheld the lower court, but the Supreme Court reversed the decision.
The distinction between a private person and a public official is pivotal in libel law. To prove defamation, a private person needs to show negligence, defined as unreasonable carelessness.
But public officials must show “actual malice” to prove defamation, defined as a knowing or reckless disregard for the truth. The different standards exist to protect and encourage free-flowing public discussion.
The state Supreme Court’s decision pointed to a 1991 decision that outlined three criteria for determining what makes a public official: whether their duties relate directly to the public interest, whether they are in a position to influence resolution of public issues and whether they have “substantial responsibility” for or control over government affairs. The court found McGuire’s job didn’t meet those criteria.
Levine said the court’s decision stakes out a new position.
“It’s a big deal not only because of the stripping of protections of students and parents who want to criticize a high school coach,” she said, but also because the court’s logic could be parsed for guidance on whether teachers are public figures. The state Court of Appeals ruled in 1995 that teachers are public officials and open to broader criticism.
Justices in Wednesday’s ruling pointedly noted that the decision wasn’t pinned on the 1995 case and that it didn’t address the issue of whether teachers are public figures.
Chance Mark said McGuire, who is no longer coaching, had suffered from his inability to protect himself. Bowlin and Danielson, who represented themselves in the case, could not be reached for comment.