Supreme Court of the United States · 2024-03-15
42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
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; claim:
Uncertainty
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.
Element color-of-law: 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.
Element color-of-law: 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.
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 20
| Case | Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) | Action taken "under color of" state, territorial, or D.C. law | Deprivation of a right, privilege, or immunity secured by the Constitution and laws | Personal involvement / causal connection ("subjects, or causes to be subjected") | Damages remedy (legacy CASE id; not a prerequisite for prospective relief) | Qualified immunity for government officials sued in individual capacity (Harlow v. Fitzgerald; Pearson v. Callahan) |
|---|---|---|---|---|---|---|
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | ✓ satisfied · lawNot counted: applied/superseded | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 20
| Case | Common-law absolute immunity (judicial, prosecutorial, legislative, witness functions) | Eleventh Amendment state sovereign immunity bar (official-capacity damages / retrospective relief) | Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity bar | Borrowed state personal-injury statute of limitations (42 U.S.C. § 1988; Wilson v. Garcia; Owens v. Okure) | Issue preclusion / collateral estoppel from prior state criminal or civil judgment (Allen v. McCurry) | Judicial standing prerequisite, separate from damages remedy |
|---|---|---|---|---|---|---|
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 13–18 of 20
| Case | Statutory bar on injunctive relief against a judicial officer acting in a judicial capacity (1996 amendment) | Municipal policy or custom as moving force (Monell v. Department of Social Services) | District of Columbia exclusive Act of Congress inclusion clause (1979 amendment) | Rejected extra element: separate proof of "abuse of governmental power" (Collins v. City of Harker Heights) | Federal action / Fifth Amendment claim (outside § 1983 state-law scope) | Collateral-order appellate jurisdiction over interlocutory qualified-immunity denials (Mitchell v. Forsyth; Johnson v. Jones) |
|---|---|---|---|---|---|---|
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 19–20 of 20
| Case | Appellate preservation / forfeiture of issue not raised in district court | Section 1983 malicious prosecution claim (Fourth Amendment / procedural due process) |
|---|---|---|
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 — satisfied · law (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Action taken "under color of" state, territorial, or D.C. law | satisfied Excluded from merits counts applied / superseded basis: law; party: O'Connor-Ratcliff and Zane, Poway Unified School District trustees; count: First Amendment claim for deleting comments and blocking on Facebook and Twitter; theory: Ninth Circuit "close nexus" / appearance-and-content approach to state action by an official on social media; subject: party=O'Connor-Ratcliff and Zane, Poway Unified School District trustees; count=First Amendment claim for deleting comments and blocking on Facebook and Twitter; theory=Ninth Circuit "close nexus" / appearance-and-content approach to state action by an official on social media 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. | school-board trustees' campaign pages kept after election for district business and labelled "Government Official"; critics' repetitive comments deleted and critics blocked | 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.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/205; Unicode character offsets [5540:5782] (end exclusive); SHA-256 0744a4e48523e9a82bcf20a8e1fa63496d3c6010c089ecd19c6263673e33b75c.Their Facebook pages described them as “Government Offcial[s]” and noted their offcial posi- tions.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/205; Unicode character offsets [5867:5966] (end exclusive); SHA-256 0744a4e48523e9a82bcf20a8e1fa63496d3c6010c089ecd19c6263673e33b75c.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.”Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/205; Unicode character offsets [7039:7216] (end exclusive); SHA-256 0744a4e48523e9a82bcf20a8e1fa63496d3c6010c089ecd19c6263673e33b75c.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.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/205; Unicode character offsets [8241:8486] (end exclusive); SHA-256 0744a4e48523e9a82bcf20a8e1fa63496d3c6010c089ecd19c6263673e33b75c. |
| O'Connor-Ratcliff v. Garnier — 601 U.S. 205 (2024) · Supreme Court of the United States · 2024 — not reached (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Deprivation of First Amendment rights (free speech, retaliation, free exercise, petition) | not_reached Excluded from merits counts applied / merits party: Christopher and Kimberly Garnier, parents blocked from the trustees' pages; count: First Amendment claim for deleting comments and blocking on Facebook and Twitter; subject: party=Christopher and Kimberly Garnier, parents blocked from the trustees' pages; count=First Amendment claim for deleting comments and blocking on Facebook and Twitter Merits of the First Amendment claim not reached; the judgment was vacated on the state-action question alone. | Unspecified route | No source quotation recorded for this block. |