The U.S. Court of Appeals for the Third Circuit affirmed a jury verdict Tuesday that rejected First Amendment retaliation claims brought by a Williamsport police officer against city officials. The court's non-precedential decision in *Helm v. Slaughter* upheld the lower court's handling of the case involving Lieutenant Steven Helm's claims against the City of Williamsport and two of its mayors.
Circuit Judge Stephanos Bibas wrote the opinion affirming the district court's decision, with Chief Judge Michael Chagares and Circuit Judge Mascott joining. The appeal arose from case number 4:21-cv-00705 in the U.S. District Court for the Middle District of Pennsylvania, where Magistrate Judge William I. Arbuckle presided.
Helm, a career law enforcement officer who joined the Williamsport Police Department as a patrolman in 1993, filed the lawsuit alleging that city officials retaliated against him for exercising his First Amendment rights. The officer was promoted multiple times throughout his career, reaching the rank of lieutenant in 2008. His current legal dispute follows a pattern of conflict with city leadership over his union activities.
The background of the case reveals a history of tension between Helm and city officials. In 2017 and 2018, he filed separate lawsuits against the City of Williamsport alleging First Amendment retaliation related to his union activities. Both cases were settled in June 2019, but the resolution did not end the ongoing disputes.
The current litigation centers on events that occurred after the earlier settlements. In 2019, then-Mayor Gabriel Campana appointed another lieutenant to an open Assistant Chief of Police position, bypassing Helm for the promotion. The Assistant Chief position became vacant again in September 2020, this time during Mayor Derek Slaughter's administration. When Helm applied for the position, Mayor Slaughter selected a different candidate.
Helm alleged that the city's failure to promote him to Assistant Chief constituted retaliation for his protected First Amendment activities, particularly his union involvement. The case proceeded to trial in federal district court, where a jury heard evidence about the promotion decisions and the circumstances surrounding Helm's claims.
After deliberating, the jury returned a verdict in favor of all defendants, including both mayors and the City of Williamsport. The jury's decision effectively rejected Helm's claims that the promotion decisions were motivated by retaliation for his protected speech and union activities.
Unsatisfied with the outcome, Helm appealed the decision to the Third Circuit Court of Appeals. His appeal focused on challenging two specific evidentiary rulings made by the trial court during the proceedings. Helm argued that these rulings were erroneous and that they warranted a new trial.
The Third Circuit panel reviewed Helm's arguments but found them insufficient to overturn the jury's verdict. In their opinion filed February 3, 2026, the appellate judges concluded that the trial court's evidentiary rulings were proper and did not provide grounds for a new trial.
The court's decision was submitted under Third Circuit Local Appellate Rule 34.1(a), which governs certain procedural aspects of appeals. The case was submitted to the court on December 2, 2025, and the opinion was filed just over two months later.
Importantly, the Third Circuit's decision is designated as "not precedential," meaning it does not establish binding legal precedent for future cases. According to the court's Internal Operating Procedure 5.7, such dispositions do not constitute binding precedent that lower courts must follow in similar cases.
The ruling represents a complete victory for the defendants in the case. The City of Williamsport, Mayor Derek Slaughter, and former Mayor Gabriel Campana successfully defended against Helm's retaliation claims both at trial and on appeal. The decision validates the jury's finding that the promotion decisions were not motivated by improper retaliation.
For Helm, the decision marks the end of his legal challenge to the promotion decisions, at least in federal court. The officer's lengthy career with the Williamsport Police Department began over three decades ago, and his various legal disputes with city officials have spanned multiple administrations and several years.
The case highlights the ongoing challenges that public employees face when alleging retaliation for protected speech activities. While the First Amendment protects public employees' rights to speak on matters of public concern, proving that adverse employment actions were motivated by retaliation rather than legitimate job-related factors can be difficult.
First Amendment retaliation cases involving public employees require plaintiffs to demonstrate that their speech addressed matters of public concern, that their interest in speaking outweighed their employer's interest in workplace efficiency, and that the protected speech was a substantial motivating factor in the adverse employment action.
The Third Circuit's affirmance of the jury verdict suggests that Helm was unable to meet this burden of proof at trial. The jury's decision in favor of the defendants indicates that they found the city officials' explanations for the promotion decisions more credible than Helm's claims of retaliation.
With the appellate process concluded, the case appears to have reached its final resolution unless Helm pursues further appeals to the Supreme Court, which would face significant procedural hurdles given the non-precedential nature of the Third Circuit's decision.