Connecticut Fire District Facing First Amendment Suit

An elected official has filed suit against a Connecticut fire district claiming district officials have violated her First Amendment rights by prohibiting her from speaking at district board meetings. Christine Wakefield filed suit against the Dayville Fire District today in US District Court for the District of Connecticut.

Wakefield is the elected tax collector for the Dayville Fire District. Her problems reportedly began in November, 2018. Quoting from the complaint:

  • In November 2018, at the Fire District Banquet, there were a series of confrontations between Wakefield’s husband, Todd Wakefield (“Mr. Wakefield”), Dayville Deputy Chief Volunteer Firefighter and other Banquet attendees.
  • Mr. Wakefield has since resigned and is no longer a Volunteer member.
  • Since this incident, the Plainfield Fire District and it’s members have retaliated against Wakefield because of her relationship with Mr. Wakefield.
  • The Fire District refused to allow Wakefield to share an office with Fire Company employees despite longstanding practice of the tax collector sharing such space.
  • Wakefield attended all Board meeting in her capacity as the Tax Collector, a position that placed her on the Board.
  • The retaliation and harassment against Wakefield was likely driven, in part by Wakefield’s and her husband’s questions and commentary at Board meetings.
  • There was no reporting relationship between Wakefield and paid Fire District staff and volunteers.
  • Wakefield was an elected Tax Collector official reporting on her duties to the Board President.
  • During four successive Board meetings at the end of 2019 and the first two months of 2020, Wakefield’s right to speak was questioned and her participation was limited or terminated.
  • At the January 2020, meeting a Board member told Mr. Wakefield that “he will not be allowed to hijack the meeting”.
  • Chief Ide’s made a motion to limit Wakefield’s speaking at the December meeting, although no action was taken on the motion.
  • At the January 2020 meeting, a new set of rules was handed out for approval.
  • Wakefield was not allowed to see them and was told “You are not a director and once they are voted on you will get a copy”.
  • Wakefield made clear that she only wanted to do her job but the officers and members of the Dayville Fire District purposefully created a hostile environment to prevent her from performing her duties.
  • The members of the Fire District created this hostile environment as retaliation for her association with Mr. Wakefield.
  • Wakefield has suffered significant emotional distress due to the harassment and her health, including her multiple sclerosis, was severely impacted.

The complaint alleges a violation of a Connecticut General Statutes § 31-51q on free speech;  violations of the First and Fourteenth Amendments; tortious interference with a business relationship; and intentional infliction of emotional distress.

Here is a copy of the complaint:

About Curt Varone

Curt Varone has over 45 years of fire service experience and 35 as a practicing attorney licensed in both Rhode Island and Maine. His background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid on call experience. He is the author of two books: Legal Considerations for Fire and Emergency Services, (2006, 2nd ed. 2011, 3rd ed. 2014, 4th ed. 2022) and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine writing the Fire Law column.
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