CHICAGO (CN) - A fired guidance counselor whose self-help book discussed racial differences in women's vaginas and advised women to "enter the wonderful world of submissiveness" cannot seek reinstatement, the 7th Circuit ruled.
Bryan Craig was a guidance counselor and girl's basketball coach at Rich Township High School in suburban Chicago until September 2012 when the Rich Township Board of Education decided that his book, "It's Her Fault," was grounds for dismissal.
Craig describes the self-published book as a "self-help book" about relationships between men and women.
"As Craig tells it, while 'counseling people of all ages and races [he] found himself saying the same things over and over to women during sessions,'" the 19-page ruling from the 7th Circuit states. "Over the course of 'provid[ing] counseling to thousands of students, parents, clients, and friends,' Craig discovered 'a trail of popcorn leading back to it being her fault.' During these encounters with female advice-seekers, Craig determined 'that women act based on emotion alone instead of emotion plus intellect' which leads to women being unable to obtain the type of relationship they want."
Parts of the book offer everyday relationship advice, advising readers to be good listeners and to develop trust by keeping intimate details of a relationship private.
But other sections encourage woman to "discover different penis sizes," and "say more 'yes' and a lot less 'no.' He's your man, go ahead and let him turn you every which way ... [g]ive him oral sex without making the 'ugh' face."
In another part of the book, Craig graphically describes the vaginas of women of different races, comparing their color and warmth.
After losing his job, Craig sued the school district, claiming it had violated his First Amendment right to free speech and retaliated against him for publishing his book.
A federal judge dismissed the case, finding that the book does not rise to the level of a public concern protected by the Constitution.
The 7th Circuit disagreed with the lower court's reasoning, but upheld the dismissal on other grounds.
"We respectfully disagree with the district court's ultimate conclusion that just because the book happened to 'touch on a matter of public interest (relationships between men and women) does not mean that it addresses a matter of public concern,'" Judge Ann Williams wrote for a three-judge panel. "That is precisely what public concern means - speech directed to the public need only address a 'matter in which the public might be interested' in order to be eligible for First Amendment protection."
The school district's interest in restricting Craig's speech ultimately "outweighed Craig's interest in making his views known," Williams added.
Rich Township reasonably decided that students would discover the hyper-sexualized and questionable advice in "It's Her Fault," thereby making them reluctant to seek Craig's advice, impairing his effectiveness as a high school counselor.
"For example, we can easily see how female students may feel uncomfortable seeking advice from Craig given his professed inability to refrain from sexualizing females," Williams wrote. "In his book, Craig confesses a 'weakness for cleavage' and another portion of a woman's anatomy and admits that this momentarily distracts him during his encounters with women."
She added: "Is it unreasonable to think a female Rich Central student who learned that Craig believed women are not inclined to rational thought may decide against visiting his office for career or other advice? We think not. Nor would it be unreasonable to believe a high school girl would keep her relationship problems to herself knowing that Craig stressed in his book the importance of a woman's sexual 'submissiveness' to her male partner."
Although the book is protected by the First Amendment, the school district's interest in maintaining a safe counseling environment trumps Craig's speech interest, the court ruled.
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