6th CIRCUIT RULES DENIAL OF TENURE DID NOT VIOLATE CONSTITUTION

that her daughter’s friendship with Flaskamp went beyond the e-mail she had discovered. She sent an e-mail to Flaskamp warning her to stay away from her daughter and threatening her with a civil suit if she did not comply. She also told Flaskamp that she intended to tell the school about her relationship with Doe, which she believed had started prior to Doe’s graduation. After receiving this message, Flaskamp contacted her principal, Paul Smith, about Doe’s mother’s concerns. Flaskamp explained that she had mistakenly sent the “inappropriate” joke to her entire address book. She also told Smith that Doe’s mother accused her of being in an inappropriate relationship with her daughter, but Flaskamp denied the accusation, insisting that it was merely a student-teacher relationship. Smith accepted Flaskamp’s explanation. In March 2001, as Flaskamp’s four year probation was about to come to an end, Smith recommended to the school district board that Flaskamp receive tenure. That same day, however, Doe’s mother called to arrange a meeting with Smith. Four days later, Doe’s mother explained that Flaskamp’s message had been directed to her daughter, and not a larger group. Doe’s mother also recounted how Flaskamp and Doe regularly communicated by e-mail and how Flaskamp had sent Doe over a dozen greeting cards. Doe’s mother insisted that Flaskamp was “chasing after her daughter” and that the relationship had begun prior to Doe’s graduation. Smith met with Flaskamp later that day, at which point Flaskamp continued to deny the existence of any inappropriate relationship. Flaskamp also met with the president of the teachers’ union, the head of human resources and again with the principal. Smith impressed upon her the seriousness of the accusations and instructed her to sever any ties with Doe, which Flaskamp agreed to do. The following week, Flaskamp encountered Doe’s brother, who was still a student at the high school where Flaskamp worked. When she inquired after Doe, he “exploded” and threatened Flaskamp. She reported the incident to Smith, who scheduled another meeting with Doe’s mother shortly thereafter. At this meeting, Doe’s mother accused Flaskamp of instigating the confrontation with her son and reiterated her charge about Flaskamp’s relationship with her daughter. Doe’s mother also told the