Illinois Court Dismisses Defamation Suit Based on Allegations that Plaintiff Teacher Was “Anti-White” etc.
From last Friday’s Appellate Court of Illinois decision in Sebaggala v. Levinson, written by Justice Celia Gamrath and joined by Justices Sanjay Tailor and Michael Hyman:
According to the operative complaint, Sebaggala is a Black fourth-grade public-school teacher and a member of Abolition Coalition, a group of citizens who “support and advocate for diversity and anti-racism in Niles Township, Illinois schools.” Levinson is the founder of NTAC, an organization whose primary goal is “to keep politics out of schools.” Plaintiffs allege Levinson uses this platform to make “bigoted remarks” about members of minority groups.
In 2020 and 2021, Sebaggala and Levinson argued about politics and social issues on Facebook and other social media…. Levinson’s statements about Sebaggala during this period [are alleged to have] constituted “a protracted and unlawful campaign of harassment,” which we summarize as follows:
- On November 4, 2020, Sebaggala attended a Black Lives Matter protest organized by Abolition Coalition. Levinson stated on NTAC’s social media that Sebaggala was protesting “in support of inappropriate conduct by a [District 219] board member.”
- On June 8, 2021, Sebaggala attended a “Protest & Anti-Racism Celebration” hosted by Abolition Coalition to oppose police officers in schools. Levinson posted a video of the event on social media, referring to Sebaggala and other attendees as “agitators,” and opining it was unacceptable for a teacher to advocate removing officers from schools.
- On August 8, 2021, Levinson referred to Sebaggala as “anti-white, anti-semetic [sic], anti-conservative, [and] anti-moderate” in a Facebook post.
On August 31, 2021, Levinson sent a 14-page letter to Sebaggala’s employer, alleging “Sebaggala’s activity perpetuates an anti-white sentiment that is ethically and morally wrong.” In the letter, Levinson:
- States that Sebaggala and other members of Abolition Coalition engaged in “intimidation tactics,” “verbal abuse,” and “bullying” against parents and school board members, including “anti-white rhetoric” and “calling parents and board members racists, white supremacists, white nationalists, bigots, and misogynists.”
- Claims that on July 27, 2021, after the school board did not vote for Sebaggala to fill a board vacancy, “a riot nearly broke out” and some school board members “required security to escort them to their cars.”
- Provides screenshots of Sebaggala’s Facebook posts, which she characterizes as “anti-white hate speech,” “racist,” and “offensive,” and argues Sebaggala’s posts serve no purpose except to “creat[e] tension and reactions on both sides.”
- Asks, “[H]ow are white children in [Sebaggala’s] classroom being treated? … [D]oes Ms. Sebaggala’s in-person and online activity violate Title VI of the Civil Rights Act …?”
- Concludes by stating, “Please take the time to address this complaint with Ms. Sebaggala. I would like this shared with the Board of Education members, administration, and teachers of Di
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