Source: cases/42usc1983/us-601-205-oconnor-ratcliff-v-garnier.case
Case source: https://www.neochart.com/catalog/cases/clus/volume_601/205/index.html
It held that § 1983's state- action requirement was satisfed because there was a “close nexus between the Trustees' use of their social media pages and their offcial positions.”
Because the approach that the Ninth Circuit applied is different from the one we have elaborated in Lindke, we vacate the judgment below and remand the case to the Ninth Circuit for further pro- ceedings consistent with our opinion in that case.
casedsl 1.2 # author: Flash1 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /us/601/205 name O'Connor-Ratcliff v. Garnier cite 601 U.S. 205 (2024) court Supreme Court of the United States date 2024-03-15 url catalog/cases/clus/volume_601/205/index.html source ir/caselaw/clus_601.jsonl sha1=df97f5c13ee41a800066c7f5b39c512d7475b2f6 chars=9292 opinion pc : per-curiam @2753..8536 controlling ? opinion: the span runs from "Per Curiam." to the Reporter's Note; it embeds the amici footnote (@2955..5187) and page headers; the syllabus (@0..2753) and Reporter's Note (@8536..) are excluded. party trustees : O'Connor-Ratcliff and Zane, Poway Unified School District trustees party garniers : Christopher and Kimberly Garnier, parents blocked from the trustees' pages count blocking : First Amendment claim for deleting comments and blocking on Facebook and Twitter theory close-nexus : Ninth Circuit "close nexus" / appearance-and-content approach to state action by an official on social media law 42usc1983 role applied posture civil; parents sued school board trustees under § 1983 for blocking them on the trustees' public social-media pages; district court let the case proceed on the ground that the trustees acted under color of state law; CA9 affirmed, finding state action; certiorari granted; vacated and remanded per curiam for reconsideration under Lindke v. Freed result remanded element color-of-law : satisfied [law] decider court-below review vacated route public-official pattern school-board trustees' campaign pages kept after election for district business and labelled "Government Official"; critics' repetitive comments deleted and critics blocked party trustees count blocking theory close-nexus fact @5540..5782 [supports] | After they won election, the Trustees continued to use their public pages to post PUSD-related content, including board- meeting recaps, application solicitations for board positions, local budget plans and surveys, and public safety updates. fact @5867..5966 [supports] | Their Facebook pages described them as “Government Offcial[s]” and noted their offcial posi- tions. fact @6481..6583 [neutral] | The Trustees initially deleted the Garniers' comments before blocking them from commenting altogether. held @7039..7216 | It held that § 1983's state- action requirement was satisfed because there was a “close nexus between the Trustees' use of their social media pages and their offcial positions.” held @8241..8486 | Because the approach that the Ninth Circuit applied is different from the one we have elaborated in Lindke, we vacate the judgment below and remand the case to the Ninth Circuit for further pro- ceedings consistent with our opinion in that case. gloss This Court decides nothing on the element itself: it records the Ninth Circuit's finding of state action, made under an appearance-and-content approach, and vacates it because that approach differs from the Lindke test. The first `held` is the Ninth Circuit's ruling as reported; the second is this Court's disposition. ? basis: the opinion does not say on what record the Ninth Circuit ruled (it says only that the district court ruled "at summary judgment" and that the Ninth Circuit affirmed); [law] is a placeholder for a vacated ruling. ? role: the per curiam neither states nor applies a test (it refers to Lindke), so `rule-announced` has no rule quote to carry; recorded as a court-below finding, vacated. element deprivation.first-amendment : not-reached party garniers count blocking gloss Merits of the First Amendment claim not reached; the judgment was vacated on the state-action question alone.