Employee Rights: Case of Edward Lane vs. Steve Franks and Susan Burrow

Topic: HR Management
Words: 1754 Pages: 6


Human resource management in public administration is subject to relevant laws and regulations of a country. Therefore, any decision made by a public corporation is subject to laws that guide the decision-making of the body. Employees, just like any other human being, are protected by the U.S. Constitution. Americans express themselves freely by virtue of the First Amendment provisions. The case of Edward Lane vs. Steve Franks and Susan Burrow, which was decided in 2014, presented a precedent for leadership and strategic legal issues in human resource management. Although the Supreme Court’s decision on Edward Lane’s case was appropriate, punishing unethical leaders and clearly defining legal requirements can help solve leadership and legal issues in government.

Case Summary


Edward Lane was a director of the Community Intensive Training for Youth (CITY), a program that was under Central Alabama Community College (CACC). CITY’s primary objective was to help underprivileged youths in Alabama Community (Potter, 2021). As one of his duties as a director, Edward Lane conducted an audit of CITY’s expenses for accountability and transparency. Edward Lane found that Suzanne Schmitz was being paid but absent from work. Consequently, Mr. Lane terminated Suzanne Schmitz’s employment contract since she was being paid for work not done. CITY was being funded by the Federal government, and any form of fraud in the organization was criminal. Therefore, Edward Lane testified against Suzanne Schmitz, who was punished with a thirty-month jail term (Potter, 2021).

While the circumstances leading to Mrs. Schmitz’s termination and conviction were legal, CACC’s president made a suspicious decision. CACC is a public corporation whose president, Steve Franks, had the right to terminate any employee in one of its programs, including CITY. The president terminated Edward Lane and other twenty-eight employees. The termination was based on the financial difficulties that the organization was facing. Later, the terminations were rescinded, but Edward Lane and one employee. While Steve Franks was sued in his capacity, Susan Burrow was sued in her official capacity as the acting CACC’s president. The courts had three major issues to determine: whether the dismissal of Edward Lane was just, whether his actions constituted public interest, and whether he was subject to protection under the First Amendment (Potter, 2021). Although the District Court and the Eleventh Circuit ruled in favor of CACC, the Supreme Court overturned their decisions.


The case was brought before the District Court, later the Court of Appeal, and finally, the U.S. Supreme Court. The Court dismissed Edward Lane’s suit, arguing that he was legally dismissed. The Eleventh Circuit, Court of Appeal, affirmed the decision to dismiss Edward Lane’s case. The court opined that Edward Lane spoke as an employee and not a citizen. Moreover, the court backed its decision by stating that Edward Lane was bound by his official duties to investigate and dismiss Suzanne Schiotz (Francis, 2022). The Supreme Court’s decision in the case of Garcetti v. Ceballos guided the two courts (Daigle, 2022). In the case, the Supreme Court held that a public official’s speech is only protected when they are acting as private citizens and not in the execution of their official duties (Daigle, 2022). Therefore, the two courts dismissed Edward Lane’s case, finding Steve Franks and Susan Burrow not liable.

Unsatisfied with the lower courts’ decisions, Edward Lane proceeded to the U.S. Supreme Court. The court held that Edward Lane’s speech was outside the scope of his official duties since the matter was of public concern (Potter, 2021). The Supreme Court relied on various cases to make its decision. The court relied on the case of Pickering v. Board of Ed. of Township High School Dist, which provided a two-step analysis in determining a public official’s speech protection. First, a public official is not deemed to speak as a citizen if they make a speech according to their employment or ordinary duties. Second, public entities must justly treat individuals who testify against them.

The Supreme Court decided that Edward Lane’s testimony was a matter of public concern. The court stated that sworn-in testimonies are examples of citizen speech. The court reasoned that witnesses who testify in court bear an obligation to society and the court to tell the truth (Potter, 2021). In the case of Connick v. Myers corruption within a public program involves matters of public concern (Ricks, 2021). According to the court, CACC failed to demonstrate its interest that overrode the public interest (Potter, 2021). Given the circumstances, the Supreme Court dismissed the decisions of the District Court and the Eleventh Circuit (Potter, 2021). Therefore, Edward Lane’s speech was a matter of public concern and was protected under the First Amendment.

Appropriateness of the Decisions

The decisions were appropriate because they limited governments’ power over their employees. While the District Court and the Eleventh Circuit dismissed Edward Lane’s prayers, the Supreme Court granted them. Governments are public entities and can be subject to misuse of their power (Nigro & Kellough, 2014). It is significant to note that individuals working in the government may have personal interests. Consequently, they may misuse their authority by mistreating employees who expose them. Unfair treatment may include unjustified dismissal and non-payment of employees’ wages (Nigro & Kellough, 2014). In the case of City of Delray Beach v. Professional Firefighters of Delray Beach, Local 1842, International Association of Firefighters, the Supreme Court affirmed that public officials’ expectations must be met. Therefore, public entities should not mistreat their employees for their interests. Limiting the powers of public administrators is appropriate since it reduces violations of powers vested in government management.

Additionally, the decision was appropriate since it sustained public morals and Biblical provisions. Corruption is unethical behavior that is unacceptable in many societies and Christianity (Sukhonos et al., 2021). The Bible warns people against corrupt actions and provides that they are subject to punishment. In Isiah 1:4, the Bible states, “Woe to the sinful nation, a people whose guilt is great, a brood of evildoers, children given to corruption…” (Thinane, 2021). Edward Lane’s actions of dismissing Suzanne Schmitz were ethical since he found her unfit as was decided in the Supreme Court case of Suzanne Magill vs. Bartlett Towing Inc. The Bible encourages public officers to be honest and exercises their authority without ill intentions. The Supreme Court’s decision to dismiss CACC’s claims was ethical, promoting moral and Biblical standing against corruption in public offices.

Key Strategic Issues and Challenges as Presented in the Case

The case of Edward Lane vs. Steve Franks and Susan Burrow presented two major strategic issues in the human resource management of public entities. Firstly was the issue of leadership integrity among public administrators. Public organizations, including the government, face the challenge of recruiting ethical leaders who are corruption free. Edward Lane exposed CACC’s dishonest leadership of employing ghost workers. Additionally, the decision of dismissing Edward Lane was unjust as was decided in the case of Suzanne Magill vs. Bartlett Towing Inc. Unethical human resource management is detrimental to organization growth and development (Ruiz‐Palomino et al., 2021). In the prevailing case, the hiring of Suzanne Schmitz led to misuse of the funds within CITY.

Secondly, the case presented an issue of difficulty in interpreting legal directives by public administrators. CACC maintained that it legally dismissed Edward Lane to manage the prevailing financial difficulties. CACC’s management failed to understand the role of public interest in its key decisions and strategies. Leadership and legal challenges are common in human resource management. Appropriate interpretation of legal instruments helps organizations avoid extra costs associated with legal fees. Moreover, misinterpretation of law can lead to a lack of public trust in the government. While CACC gave vague reasons for Edward Lane’s dismissal, the public was already aware of funds misappropriation in the program. Although the court decision was appropriate, further solutions could have been taken to solve the two strategic challenges.


Leadership Integrity Challenges

Although the Supreme Court’s decision in the case of Edward Lane vs. Steve Franks and Susan Burrow was appropriate, the court could have provided other alternative solutions. First, the court could have clearly defined the punishments available for public administrators who misuse their power when executing their official duties. The court could have ignored the immunity available to Steve Franks, and given appropriate punishment. The most appropriate punishment would be declaring Steve Franks unfit to hold public office. The solution is relevant to the case since it would allow CACC to take action against Steve Franks.

Punishing corrupt public officer deters such behaviors and promotes the Biblical perspectives on dishonest administration. Hosea 9:9 provides that corrupt actions and iniquities should be punished (Bible Gateway, n.d.). Consequently, punishing unethical public administrators promotes Christian moral standing. Public administrators have a moral duty to make decisions that are ethical, regardless of their interests (Sifuna-Evelia, 2017). Additionally, the Bible requires public officers to act per God’s instructions and avoid dishonest behaviors. In implementing this solution, the Supreme Court could draft legal advice to public organizations on the kind of punishment for dishonest behaviors. Additionally, the move could open the window for legislating an Act that prohibits and punishes misuse of power by public officials.

Interpreting Legal Instrument Challenges

Although the court gave a legal opinion on why Edward Lane was unjustly dismissed, it failed to give legal directions which are crucial for human resource management. The Supreme court properly left the Constitutional questions raised for another day (Legal Information Institute, n.d.). Such a decision was inappropriate since individual rights and matters of public interest should be prioritized. The court could have given a clear solution on the position of a constitutional right in public administration. The solution is relevant to the case since Edward Lane would have been remedied. The Supreme Court could offer a legal opinion on the limitations of human rights in case of unfair dismissal to implement the solution. Consequently, public entities could describe the scope of human rights in their ethical codes.


Human resource management in government entities is a matter of public interest. The government utilizes funds that are collected from citizens. The case of Edward Lane vs. Steve Franks and Susan Burrow helped in determining the limitation of public administrators. The case decision helped in protecting whistle-blowers within public entities in the U.S. Although the decision was appropriate, the Supreme Court ought to have punished Steve Franks in his capacity to deter such actions in the future. Therefore, the U.S. legal system plays a crucial role in regulating the exercise of human resource management and the execution of public authority.


‌ Ricks, R. (2021). The First Amendment, Twitter, and Dr. Bandy Lee. AELJ Blog. Web.

Bible Gateway. (n.d.). Hosea 9:9 ESV. Web.

City of Delray Beach v. Professional Firefighters of Delray Beach., 636 So. 2d 157 (Fla. Dist. Ct. App. 1994).

Connick v. Myers, 461 U.S. 138, 103 S. Ct. 1684, 75 L. Ed. 2d 708 (1983).

Daigle, H. (2022). Critical race theory through the lens of Garcetti v. Ceballos. First Amendment Law Review, 20, pp. 118. Web.

Francis, M. (2022). Don’t Let the Truth Get Snowden: Why United States and International Whistleblowing Laws and Protections Need Reform. [Doctoral dissertation, Appalachian State University]. Web.

Garcetti v. Ceballos, 547 U.S. 410, 126 S. Ct. 1951, 164 L. Ed. 2d 689 (2006).

Lane v. Franks, 134 S. Ct. 2369, 573 U.S. 228, 189 L. Ed. 2d 312 (2014).

Legal Information Institute (n.d.). Lane v. Franks. Cornell Law School. Web.

Magill v. Bartlett Towing, Inc., 35 So. 3d 1017 (Fla. Dist. Ct. App. 2010).

Nigro, L. G., & J Edward Kellough. (2014). The new public personnel administration. Wadsworth Cengage Learning.

Pickering v. Board of Ed. of Township High School Dist. 205, Will Cty., 391 U.S. 563, 88 S. Ct. 1731, 20 L. Ed. 2d 811 (1968).

Potter, K. (2021). To Tell the truth: Public employee First Amendment rights in providing testimony. SPNHA Review, 17(1). Web.

Ruiz‐Palomino, P., Martínez‐Cañas, R., & Bañón‐Gomis, A. (2021). Is unethical leadership a negative for Employees’ personal growth and intention to stay? The buffering role of responsibility climate. European Management Review, 18(3), pp. 535-549

Sifuna-Evelia, M. (2017). Human Resource Management Practices: A Biblical Perspective. Partridge Singapore.

Sukhonos, V., Pavlenko, L., Krukhmal, O., Ivanovska, A., & Maletov, D. (2021). Forms of committing corrupt abuses of public finances and ways to counteract them in Ukraine. Amazonia Investiga, 10(39), pp. 149-158.

Thinane, J. S. (2021). Thuma Mina – an Isaiah 6:8 perspective in crossfire with Step-aside: SA ruling party’s moral restoration efforts. Pharos Journal of Theology.

Discussion: Human Resource Management
International Human Resource Management of Unilever in Africa