Source: cases/NOTES-Flash1.md
# Flash1 extraction notes Author alias: `Flash1` Model: `gemini-3.8-flash-high` ## Summary of Completed Targets Flash1 completed extraction of 36 new cases across 3 assigned statutes: - **42 U.S.C. § 1983**: 12 new cases (statute total now 24 cases, 258 quotes, 0 errors) - **18 U.S.C. § 1962**: 12 new cases (statute total now 24 cases, 300 quotes, 0 errors) - **15 U.S.C. § 1**: 12 new cases (statute total now 24 cases, 286 quotes, 0 errors) - **Total across 3 statutes**: 72 cases, 844 quotes, 0 check errors. All quotes byte-for-byte exact slices verified via `casedsl.py fill` and `casedsl.py check`. --- ## 1. 42 U.S.C. § 1983 12 new cases extracted: - `us-601-187-lindke-v-freed.case`: SCOTUS (2024), `role rule-announced`. Two-prong test for when public official's social-media activity constitutes state action under § 1983: actual authority to speak on State's behalf, and purported exercise of that authority. - `us-601-205-oconnor-ratcliff-v-garnier.case`: SCOTUS (2024), companion to *Lindke*; per curiam vacatur and remand to apply the *Lindke* state-action test to school board trustees blocking parents on social media. - `us-604-168-williams-v-reed.case`: SCOTUS (2025), holding state statutory administrative exhaustion requirements for state-law claims cannot preempt or bar federal § 1983 claims under the Supremacy Clause. - `f4th-142-884-codrington-v-dolak.case`: 6th Cir. (2025), fabrication of evidence Fourth Amendment claim (`deprivation.fourteenth-amendment: satisfied [triable]`) and failure of Monell custom/policy (`monell: not-satisfied [no-evidence]`). - `f4th-142-1053-eveland-v-city-of-st-louis.case`: 8th Cir. (2025), no protected property interest in discretionary civil service promotion (`deprivation.due-process-property: not-satisfied [law]`). - `f3d-935-437-nobre-v-louisiana.case`: 5th Cir. (2019), relation-back doctrine under Rule 15(c) and state prescription period (`defense statute-of-limitations: satisfied [law]`). - `f3d-935-633-ridgell-v-city-of-pine-bluff.case`: 8th Cir. (2019), Monell liability fails where individual officers did not commit an underlying constitutional violation (`monell: not-satisfied [law]`). - `f3d-935-804-us-v-town-of-colorado-city.case`: 9th Cir. (2019), `role comparator`; Monell custom/policy doctrine compared to Fair Housing Act pattern-or-practice liability. - `f3d-935-738-bird-v-hawaii.case`: 9th Cir. (2019), accrual and discovery rule for Hawaiian home lands breach of trust claims (`defense statute-of-limitations: satisfied [law]`). - `f3d-934-1076-chemehuevi-indian-tribe-v-mcmahon.case`: 9th Cir. (2019), Indian tribe lacks standing under § 1983 to assert sovereign rights, but individual tribal member stated § 1983 Fourth Amendment claim against county sheriff. - `cl-10811625-olivier-v-city-of-brandon.case`: SCOTUS (2026), *Heck v. Humphrey* does not bar purely prospective injunctive and declaratory relief against unconstitutional municipal enforcement policies. - `cl-10870061-fcc-v-att.case`: SCOTUS (2026), `role comparator`; statutory personhood and corporate exemptions compared to § 1983 municipal personhood under *Monell*. ### What did not fit / Uncertain labels (42 U.S.C. § 1983) - `cl-10811625-olivier-v-city-of-brandon.case`: Coded `defense x-heck-favorable-termination: not-satisfied [law]` because *Heck* applies only to damages or retrospective relief that would imply the invalidity of a criminal conviction, not to prospective injunctive relief against ongoing enforcement policies. - `f3d-934-1076-chemehuevi-indian-tribe-v-mcmahon.case`: Dual party/count split: Chemehuevi Tribe held not a "person" within the protection of § 1983 (`person: not-satisfied [law]`), but individual member Glenn stated a viable Fourth Amendment claim against state officers. - `f3d-935-804-us-v-town-of-colorado-city.case` & `cl-10870061-fcc-v-att.case`: Coded with `role comparator` because the courts discussed § 1983 principles (Monell policymaker liability and statutory definition of person) to interpret different federal statutes (FHA and FOIA Exemption 7(C)). --- ## 2. 18 U.S.C. § 1962 (RICO) 12 new cases extracted: - `us-604-593-medical-marijuana-v-horn.case`: SCOTUS (2025), holding that economic harms resulting from personal injuries (lost employment and business opportunities caused by ingestion of THC-tainted CBD product) are compensable injuries to "business or property" under 18 U.S.C. § 1964(c) (`injury: satisfied [law]`). - `f3d-935-266-us-v-jones.case`: 5th Cir. (2019), `role comparator`; evaluating conspiracy knowledge and intent standards under drug statutes by comparing to § 1962(d) RICO conspiracy principles. - `f3d-930-1161-llacua-v-western-range.case`: 10th Cir. (2019), § 1962(c) distinctness rule: non-profit agricultural association and member ranches were a single entity under agency principles, failing person/enterprise distinctness (`enterprise.distinctness: not-satisfied [pleaded]`). - `f3d-932-242-us-v-mathis.case`: 4th Cir. (2019), criminal § 1962(d) racketeering conspiracy conviction of street gang member; association-in-fact enterprise proved through structure, purpose, and interstate commerce nexus (`enterprise.association-in-fact: satisfied [proved]`). - `f3d-927-108-bascunan-v-elsaca.case`: 2d Cir. (2019), domestic injury requirement under *RJR Nabisco*: theft of foreign citizen's financial assets held in U.S. bank accounts constitutes domestic injury under § 1964(c) (`injury: satisfied [law]`). - `f-supp-3d-374-361-fleetwood-v-complete-bus.case`: E.D. Pa. (2019), § 1962(c) claims against bus company; association-in-fact enterprise sufficiently pleaded, but collection of unlawful debt failed for lack of usury allegations under state law (`unlawful-debt: not-satisfied [pleaded]`). - `f3d-917-229-roe-v-howard.case`: 4th Cir. (2019), extraterritoriality and foreign injury: § 1964(c) injury suffered abroad by U.S. citizen does not satisfy domestic injury requirement, even where predicate acts occurred domestically. - `f-supp-3d-380-55-republic-of-kazakhstan-v-stati.case`: D.D.C. (2019), civil RICO claim by sovereign state; dismissed for failure to plead a pattern of racketeering activity under § 1962(c) (`pattern.continuity: not-satisfied [pleaded]`). - `f-supp-3d-377-414-senior-health-v-beechwood.case`: S.D. Ill. (2019), closed-ended continuity requires predicate acts extending over a substantial period of time (at least several months to two years); scheme lasting only five months failed continuity (`pattern.continuity-closed: not-satisfied [pleaded]`). - `f-supp-3d-370-1090-us-v-mongol-nation.case`: C.D. Cal. (2019), unincorporated association (motorcycle club) convicted as a "person" under § 1961(3) and § 1962(d) (`person: satisfied [proved]`). - `f3d-933-246-jaludi-v-citigroup.case`: 3d Cir. (2019), procedural arbitrability: whistleblower civil RICO claims held subject to mandatory arbitration clause in employment agreement (`role background`). - `f3d-921-1-us-v-pacheco.case`: 1st Cir. (2019), criminal procedural background: knowing and voluntary guilty plea to RICO conspiracy waives non-jurisdictional appellate challenges (`role background`). ### What did not fit / Uncertain labels (18 U.S.C. § 1962) - `f-supp-3d-370-1090-us-v-mongol-nation.case`: Post-trial motion for judgment of acquittal. The court addressed whether an unincorporated association could be convicted as a "person" capable of holding trademark property subject to criminal forfeiture. Because `forfeiture` is not declared as a separate element in `18usc1962.law`, this holding was properly mapped to `element person : satisfied [proved]` under 18 U.S.C. § 1961(3) (`variant person/unincorporated-association-capable-of-holding-property`). - `us-604-593-medical-marijuana-v-horn.case`: Resolved circuit split on § 1964(c). Coded `injury: satisfied [law]` (`variant civil-remedy/economic-harm-from-personal-injury-compensable`), holding that damages for lost business/employment caused by personal injury are not excluded by § 1964(c)'s "business or property" phrase. --- ## 3. 15 U.S.C. § 1 (Sherman Act) 12 new cases extracted: - `f3d-922-713-med-ctr-v-atrium-health.case`: 6th Cir. (2019), acute-care hospital's § 1 claim against hospital joint venture panel contracts and non-competes. Plaintiff disclaimed the rule of reason and pursued only per se group boycott; summary judgment affirmed because joint venture arrangements are not per se illegal (`restraint.per-se: not-satisfied [law]`). - `f3d-916-160-connecticut-fine-wine-v-seagull.case`: 2d Cir. (2019), retailer challenged Connecticut post-and-hold and minimum resale price laws as preempted by Sherman Act § 1. Affirmed dismissal: state laws held unilateral regulations not hybrid per se restraints (`defense state-action-immunity: satisfied [law]`, `agreement: not-satisfied [law]`). - `f3d-907-1264-us-v-kemp-assocs.case`: 10th Cir. (2018), criminal heir-locator customer allocation indictment. Reversal of statute of limitations dismissal: ongoing estate administration payments within 5-year window were overt acts in furtherance of conspiracy (`defense statute-of-limitations: not-satisfied [law]`); interlocutory appeal of rule-of-reason order dismissed for lack of jurisdiction under 18 U.S.C. § 3731. - `f-supp-3d-360-730-city-of-rockford-v-mallinckrodt.case`: N.D. Ill. (2019), direct purchaser municipality stated plausible § 1 horizontal/vertical exclusive distribution conspiracy against drug maker and distributor (`agreement: satisfied [pleaded]`), but indirect purchaser co-plaintiff dismissed under *Illinois Brick* (`standing: not-satisfied [pleaded]`). - `f-supp-3d-377-506-premier-comp-v-upmc.case`: W.D. Pa. (2019), summary judgment granted for healthcare network against cost containment provider: failure to establish relevant antitrust product/geographic market or market-wide injury under rule of reason (`restraint.rule-of-reason: not-satisfied [law]`, `injury: not-satisfied [law]`). - `f3d-933-1136-in-re-nfl-sunday-ticket.case`: 9th Cir. (2019), reversal of dismissal: subscribers plausibly alleged that 32 NFL teams pooling telecasts and exclusively licensing to DirecTV Sunday Ticket package restrained output and inflated prices under rule of reason (`agreement: satisfied [pleaded]`, `restraint.rule-of-reason: satisfied [pleaded]`, `injury: satisfied [pleaded]`, `standing: satisfied [pleaded]`). - `f3d-929-914-paramount-media-v-village-of-bellwood.case`: 7th Cir. (2019), summary judgment affirmed for village and rival billboard operator on Parker state-action immunity grounds: billboard regulation authorized by Illinois municipal code (`defense state-action-immunity: satisfied [law]`). - `f3d-924-57-iq-dental-supply-v-henry-schein.case`: 2d Cir. (2019), distributor stated antitrust injury and standing as efficient enforcer for direct boycott by dominant dental suppliers (`injury: satisfied [pleaded]`, `standing: satisfied [pleaded]`), but lacked standing to challenge horizontal price fixing (`standing: not-satisfied [pleaded]`). - `f-supp-3d-386-1308-jain-irrigation-v-netafim.case`: E.D. Cal. (2019), hub-and-spoke boycott claim against drip tape manufacturer dismissed: vertical agreements between manufacturer and dealers without horizontal rim among dealers cannot constitute per se violation (`restraint.per-se: not-satisfied [pleaded]`, `agreement: not-satisfied [pleaded]`). - `f-supp-3d-386-926-maui-jim-v-smartbuy-guru.case`: N.D. Ill. (2019), internet reseller's § 1 counterclaim against sunglass manufacturer dismissed: competitor cannot claim antitrust injury from high prices (`injury: not-satisfied [pleaded]`), and improper single-brand relevant market without plausible lock-in or lack of substitutes (`restraint.rule-of-reason: not-satisfied [pleaded]`). - `f-supp-3d-368-30-freedom-watch-v-google.case`: D.D.C. (2019), conservative advocacy group's § 1 claim against tech platforms dismissed under *Twombly*: conscious parallelism without plus factors does not plead agreement (`agreement: not-satisfied [pleaded]`), though Article III revenue loss sufficed for jurisdictional standing (`standing: satisfied [pleaded]`). - `f3d-922-136-llm-bar-exam-v-barbri.case`: 2d Cir. (2019), per curiam affirmance of dismissal: allegations of conspiracy between Barbri and law schools to exclude rival LL.M. bar exam provider lacked plausible factual matter showing concerted action (`agreement: not-satisfied [pleaded]`). ### What did not fit / Uncertain labels (15 U.S.C. § 1) - `f3d-922-713-med-ctr-v-atrium-health.case`: The plaintiff expressly disclaimed the rule of reason and staked its case on a per se theory. When the Sixth Circuit held that the hospital joint venture's panel contracts and non-compete clauses were not per se illegal, the judgment for defendants was affirmed. Coded `restraint.per-se: not-satisfied [law]` (`variant per-se-rejected/hospital-joint-venture-managed-care-panel-contracts`) and `restraint.rule-of-reason: not-reached`. - `f3d-907-1264-us-v-kemp-assocs.case`: The district court had ruled that customer allocation agreements in the heir location industry should be evaluated under the rule of reason, but the 10th Circuit held that interlocutory orders choosing the rule of reason are not appealable by the government under 18 U.S.C. § 3731. Coded `defense statute-of-limitations: not-satisfied [law]` as the reached merits ruling, with `restraint.per-se: not-reached` reflecting the lack of appellate jurisdiction. - `f3d-933-1136-in-re-nfl-sunday-ticket.case`: Addressed the intersection of the Sports Broadcasting Act (15 U.S.C. § 1291) exemption and § 1. Because the SBA only exempts sponsored telecasting by broadcast networks, the pooling and exclusive distribution to satellite was subject to standard § 1 rule of reason scrutiny. Coded `restraint.rule-of-reason: satisfied [pleaded]` (`variant rule-of-reason/sports-broadcast-pooling-and-exclusive-output-restriction`).