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: rule-announced; posture: civil; citizen sued city manager under § 1983 alleging a First Amendment violation after the manager deleted his comments and blocked him on Facebook; district court granted summary judgment to the manager for want of state action; CA6 affirmed; certiorari granted; vacated and remanded for application of the two-part state-action test; result: remanded; claim:
Uncertainty
opinion: unanimous. The span runs from "Justice Barrett delivered the opinion of the Court" to the Reporter's Note; it embeds the amici footnote (@9347..11275), page headers, and footnote 3 after "It is so ordered."; the syllabus (@0..8843) and Reporter's Note (@41080..) are excluded.
Element color-of-law: polarity: the Court applies nothing; polarities follow its own test (appearance alone cannot supply authority, so the "City Manager" self-description supports only at the second step).
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) |
|---|---|---|---|---|---|---|
| Lindke v. Freed — 601 U.S. 187 (2024) · Supreme Court of the United States · 2024 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | ○ not reached · basis not recordedNot counted: rule-announced/merits | · 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 |
|---|---|---|---|---|---|---|
| Lindke v. Freed — 601 U.S. 187 (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) |
|---|---|---|---|---|---|---|
| Lindke v. Freed — 601 U.S. 187 (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) |
|---|---|---|
| Lindke v. Freed — 601 U.S. 187 (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 |
|---|---|---|---|---|
| Lindke v. Freed — 601 U.S. 187 (2024) · Supreme Court of the United States · 2024 — not reached (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Action taken "under color of" state, territorial, or D.C. law | not_reached Excluded from merits counts rule-announced / merits party: James Freed, city manager of Port Huron, sued in his individual capacity; count: First Amendment claim for deleting comments and blocking on Facebook; theory: whether an official's posts on a mixed personal / job-related social-media page are state action; subject: party=James Freed, city manager of Port Huron, sued in his individual capacity; count=First Amendment claim for deleting comments and blocking on Facebook; theory=whether an official's posts on a mixed personal / job-related social-media page are state action The Court announces a two-part test for when a public official's social-media activity is state action under § 1983 (actual authority to speak for the State on the matter; purporting to exercise it in the relevant posts) and does not apply it to Freed's page. | city manager's public Facebook page mixing personal and job-related posts, neither labelled personal nor official; critic's comments deleted and critic blocked | He described himself as “Daddy to Lucy, Husband to Jessie and City Manager, Chief Administrative Offcer for the citizens of Port Huron, MI.”Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [13399:13539] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101.And, as before his appointment, Freed posted prolifically (and primarily) about his personal life.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [13609:13707] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101.We hold that such speech is attribut- able to the State only if the offcial (1) possessed actual au- thority to speak on the State's behalf, and (2) purported to exercise that authority when he spoke on social media.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [11927:12143] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101.In sum, a defendant like Freed must have actual authority rooted in written law or longstanding custom to speak for the State.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [33251:33377] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101.The state-action doctrine requires Lindke to show that Freed (1) had actual authority to speak on behalf of the State on a particular matter, and (2) purported to exercise that authority in the relevant posts.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [40199:40408] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101.To the extent that this test differs from the one applied by the Sixth Circuit, we vacate its judgment and remand the case for further proceedings consistent with this opinion.Source: docroot/ir/caselaw/clus_601.jsonl#/us/601/187; Unicode character offsets [40409:40585] (end exclusive); SHA-256 52e95c6050e67173cc6ac2d8b57671fc706ef84b7358ea5b127323e1c6ac8101. |
| Lindke v. Freed — 601 U.S. 187 (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 rule-announced / merits party: Kevin Lindke, the blocked commenter; count: First Amendment claim for deleting comments and blocking on Facebook; subject: party=Kevin Lindke, the blocked commenter; count=First Amendment claim for deleting comments and blocking on Facebook Merits of the First Amendment claim not reached: the case was remanded on the threshold state-action inquiry. | Unspecified route | No source quotation recorded for this block. |