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O’Connor-Ratcliff v. Garnier

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Supreme Court of the United States
O’Connor-Ratcliff v. Garnier
Term: 2023
Important Dates
Argued: October 31, 2023
Decided: March 15, 2024
Outcome
Vacated and remanded
Vote
N/A
Majority
Per curiam

O’Connor-Ratcliff v. Garnier is a case that was decided by the Supreme Court of the United States on March 15, 2024, during the court's October 2023-2024 term. The case was argued on October 31, 2023.

In a per curiam ruling issued on March 15, 2024, the Court vacated the United States Court of Appeals for the Ninth Circuit ruling and remanded the case for further proceedings, holding, "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 proceedings consistent with our opinion in that case."[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the First Amendment and public officials’ social media behavior. Click here to learn more about the case's background.
  • The questions presented: “Whether a public official engages in state action subject to the First Amendment by blocking an individual from the official's personal social-media account, when the official uses the account to feature their job and communicate about job-related matters with the public, but does not do so pursuant to any governmental authority or duty.”[2]
  • The outcome: The U.S. Supreme Court vacated the United States Court of Appeals for the Ninth Circuit ruling and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:[3]

    Background

    As of October 2022, Michelle O’Connor-Ratcliff and T.J. Zane were on the Poway Unified School District Board of Trustees in Poway, California.[5] Before they were elected to the board in 2014, they created public Facebook pages for their campaigns and political activities. O’Connor-Ratcliff also created a public Twitter page before 2017. In addition to the pages, they had private Facebook profiles. After being elected, O’Connor-Ratcliff and Zane updated their personal profiles to include their new board positions and share information regarding the school district.[6]

    Christopher and Kimberly Garnier are parents to students of the Poway Unified School District. They often left comments critical of the trustees and the school board on O’Connor-Ratcliff and Zane’s public pages, sometimes repeatedly posting the same criticisms.[7] At first, O’Connor-Ratcliff and Zane deleted or hid the parents’ comments, but around October 2017, they blocked the Garniers from their Facebook and Twitter pages.[8]

    The Garniers sued O’Connor-Ratcliff and Zane in the United States District Court for the Southern District of California. The Garniers argued that the trustees’ social media pages were public forums and that, by blocking them, the trustees were violating their First Amendment rights.[7] The district court ruled in favor of the Garniers, granting them declaratory relief and injunctive relief. However, the court also found that the Trustees had qualified immunity relating to the Garniers' damages claims. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision.[8]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether a public official engages in state action subject to the First Amendment by

    blocking an individual from the official's personal social-media account, when the official uses the account to feature their job and communicate about job-related matters with the public, but does not do so pursuant to any governmental authority or duty. [9]

    		”

    Oral argument

    Audio

    Audio of oral argument:[10]



    Transcript

    Transcript of oral argument:[11]

    Outcome

    In a per curiam ruling issued on March 15, 2024, the Court vacated the United States Court of Appeals for the Ninth Circuit ruling and remanded the case for further proceedings, holding, "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 proceedings consistent with our opinion in that case."[1]


    Opinion

    In the court's per curiam opinion, the Court held:[1]

    “ In 2014, Michelle O’Connor-Ratcliff and T. J. Zane created public Facebook pages to promote their campaigns for election to the Poway Unified School District (PUSD) Board of Trustees. While O’Connor-Ratcliff and Zane (whom we will call the Trustees) both had personal Facebook pages that they shared with friends and family, they used their public pages for campaigning and issues related to PUSD. 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. They also used their pages to solicit feedback and communicate with constituents. Their Facebook pages described them as “Government Official[s]” and noted their official positions. O’Connor-Ratcliff also created a public Twitter page, which she used in much the same way.


    Christopher and Kimberly Garnier, who have children attending PUSD schools, often criticized the board of trustees. They began posting lengthy and repetitive comments on the Trustees’ social-media posts—for instance, nearly identical comments on 42 separate posts on O’Connor-Ratcliff ’s Facebook page and 226 identical replies within a 10-minute span to every tweet on her Twitter feed. The Trustees initially deleted the Garniers’ comments before blocking them from commenting altogether.

    The Garniers sued the Trustees under 42 U. S. C. §1983, seeking damages and declaratory and injunctive relief for the alleged violation of their First Amendment rights. At summary judgment, the District Court granted the Trustees qualified immunity as to the damages claims but al- lowed the case to proceed on the merits on the ground that the Trustees acted “under color of ” state law when they blocked the Garniers. §1983.

    The Ninth Circuit affirmed. It held that §1983’s state-action requirement was satisfied because there was a “close nexus between the Trustees’ use of their social media pages and their official positions.” 41 F. 4th 1158, 1170 (2022). The court cited its own state-action precedent, which holds that an off-duty state employee acts under color of law if she (1) “purports to or pretends to act under color of law”;(2) her “pretense of acting in the performance of [her] duties had the purpose and effect of influencing the behavior of others”; and (3) the “harm inflicted on plaintiff related ins ome meaningful way either to the officer’s governmental status or to the performance of [her] duties.” Ibid. (citing Naffe v. Frey, 789 F. 3d 1030, 1037 (CA9 2015); internal quotation marks and alterations omitted). Applying that framework, the court found state action based largely on the official “appearance and content” of the Trustees’ pages.41 F. 4th, at 1171.

    We granted certiorari in this case and in Lindke v. Freed, ___ U. S. ___ (2024), to resolve a Circuit split about how to identify state action in the context of public officials using social media. 598 U. S. ___ (2023). 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 proceedings consistent with our opinion in that case.[9]

    		”

    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[12]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 U.S. Supreme Court, O’Connor-Ratcliff v. Garnier, decided March 15, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "22-324 O'CONNOR-RATCLIFF V. GARNIER," accessed April 27, 2023
    3. ↑ U.S. Supreme Court, "No. 22-324," accessed April 27, 2023
    4. ↑ Casetext, "Garnier v. O'Connor-Ratcliff," accessed April 27, 2023
    5. ↑ U.S. Supreme Court, "No. 22-324," accessed December 18, 2023
    6. ↑ U.S. Supreme Court', "Michelle O’connor-Ratcliff and T.J. Zane V. Christopher Garnier and Kimberly Garnier, On Petition for a Writ of Certiorari to the United States Court of Appeals for the Ninth Circuit," accessed December 18, 2023
    7. ↑ 7.0 7.1 Casetext’', "Garnier v. O'Connor-Ratcliff" accessed December 18, 2023
    8. ↑ 8.0 8.1 Oyez’', "O'Connor-Ratcliff v. Garnier," accessed December 18, 2023
    9. ↑ 9.0 9.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 31, 2023
    11. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 31, 2023
    12. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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