Chateaubriand

We must decide whether state legislators are immune from suit for allegedly firing an employee who opposed performing illegal political campaign activity.

I

In 1985 the Washington State Senate Democratic Caucus (the “Caucus”) hired Francisco Chateaubriand as a public information officer in its communications department. Chateaubriand was promoted to the position of Communications section Coordinator in April 1990. The Communications section Coordinator managed personnel who prepared and distributed press materials, newsletters, questionnaires, speeches, and other materials for senators.

In the fall of 1990, Chateaubriand grew concerned that staff members of the Caucus were engaged in illegal campaign activity. Washington state law generally prohibits the use of state equipment, facilities, and employees’ time for political campaign • purposes. According to Chateaubriand, Paul Berendt, the Legislative Services section Coordinator, led the illegal use of staff and facilities for political campaigns. In November 1990, Marcus Gaspard was elected Democratic Leader within the Caucus, and Sid Snyder was elected Caucus Chairman. Martin Brown was appointed Caucus Staff Director.…