Außerdienstliche Aktivitäten des Arbeitnehmers als Kündigungsgrund

Außerdienstliche Aktivitäten für die NPD und JN als Kündigungsgrund

Wer Arbeitnehmer des öffentlichen Dienstes ist, muss ein bestimmtes Maß an Verfassungstreue aufbringen. Wie weit diese Verpflichtung geht, richtet sich zum einen nach der vertraglich geschuldeten Tätigkeit und zum anderen nach der jeweiligen Aufgabenstellung. Zugehörigkeit zur NPD oder auch ihrer Jugendorganisation, kurz JN, stellen für sich gesehen noch keinen Kündigungsgrund dar. Dies gilt selbst dann, wenn die Verfassungsfeindlichkeit der Organisationen – nicht ihre nur vom Bundesverfassungsgericht festzustellende Verfassungswidrigkeit – anzunehmen ist.

Beschäftigte dürfen generell nicht darauf aus sein, den Staat oder die Verfassung und deren Organe zu beseitigen, zu beschimpfen oder verächtlich zu machen. Wenn nun ein Arbeitnehmer – und sei es auch nur außerdienstlich – Aktivitäten dieser Art nachgeht, kann dies ein Grund für eine Kündigung durch seinen Arbeitgeber selbst dann sein, wenn das Verhalten für sich gesehen nicht strafbar ist.

Das Bundesarbeitsgerichts hat die Entscheidungen der Vorinstanzen bestätigt, die die Kündigung des Arbeitsverhältnisses wegen Verstoßes gegen diesen Grundsatzes für wirksam erachtet haben. Vorliegend ist der Kläger Mitglied der NPD und war seit dem Jahr 2003 in der Finanzverwaltung des beklagten Landes tätig. Im Rahmen seiner Tätigkeit hatte er Zugriff auf personenbezogene, dem Steuergeheimnis unterliegende Daten. In seiner Freizeit verbreitete er mittels elektronischer „Newsletter“ Informationen zu Treffen und Veranstaltungen eines NPD-Kreisverbands und der JN sowie Rundbriefe verschiedener Art. Im Jahr 2009 verschickte er dann einen Aufruf zur Teilnahme an einer Demonstration.

Nach dem Gesamtkontext der Äußerungen machen sich die Verfasser des Demonstrationsaufrufs für einen gewaltsamen Umsturz stark. Eine andere Deutung erscheint unmöglich. Der Kläger hat sich den Inhalt des Aufrufs zumindest dadurch zu eigen gemacht, das er ihn weiterverbreitete. Sein Vorgehen zeigt, dass er das auch ihm abzuverlangende Mindestmaß an Verfassungstreue nicht aufbringt. Die Kündigung ist jedenfalls aus Gründen in seiner Person gerechtfertigt. Grundrechte aus Art. 5 GG und Art. 12 GG stehen dem nicht entgegen.

Bundesarbeitsgericht, Urteil vom 6. September 2012 – 2 AZR 372/11 –
Vorinstanz: Landesarbeitsgericht Baden-Württemberg – Kammern Mannheim, Urteil vom 26. Januar 2011 – 19 Sa 67/10 –

vgl. Pressemitteilung 64/12 des Bundesarbeitsgerichts

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