Lambert

The City of Santa Ana, Robert Richard, its Library Department Director, and its City Manager, David Ream, defendants in a Section 1983 action, 1 appeal the judgments against them imposing liability, awarding damages, injunctive and declaratory relief, and denying qualified immunity to the individual defendants. The suit arises out of a letter of reprimand sent by Richard to Barbara Lambert, a library employee and union representative, for her statement before the City Council in her capacity as a representative of the Santa Ana City Employees Association (SACEA) criticizing Richard.

PROCEDURAL HISTORY

On November 23, 1992, the district court granted the plaintiffs’ motion for summary judgment on the issue of liability, finding all of the defendants liable for violating the plaintiffs’ First Amendment rights, and denied the defendants’ motion for summary judgment seeking dismissal. It also held that plaintiffs were entitled to declaratory and injunctive relief. On July 26, 1993, the court granted the plaintiffs’ motion for summary judgment denying qualified immunity to the individual defendants, but declined to rule on the defendants’ motion for summary judgment requesting…