O’Connor-Ratcliff v. Garnier
View Official PDFBelow are plain-language sections to help you understand what the Court decided in O’Connor-Ratcliff v. Garnier and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of O’Connor-Ratcliff v. Garnier.
The case involves Michelle O'Connor-Ratcliff and T. J. Zane, who blocked Christopher and Kimberly Garnier from commenting on their public social media pages used for school board activities. The Garniers sued, alleging a First Amendment violation, and the Ninth Circuit affirmed that the Trustees acted under state law. The Supreme Court vacated and remanded the decision due to differing interpretations of the state-action requirement.
Holding
The single most important “bottom line” of what the Court decided in O’Connor-Ratcliff v. Garnier.
The Court held that the Ninth Circuit's approach to § 1983's state-action requirement differs from the one elaborated in Lindke v. Freed.
Constitutional Concepts
These are the Constitution-related themes that appear in O’Connor-Ratcliff v. Garnier. Click a concept to see other cases that involve the same idea.
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Why Free Speech is relevant to O’Connor-Ratcliff v. Garnier
The case involves allegations of First Amendment violations due to the blocking of comments on social media pages.
Syllabus excerpt (verbatim)The Garniers sued the Trustees pursuant to 42 U. S. C. § 1983, alleging a violation of their First Amendment rights.
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Why State–Federal Power is relevant to O’Connor-Ratcliff v. Garnier
The case discusses whether the actions of the Trustees on social media were under 'color of' state law, implicating state action doctrine.
Syllabus excerpt (verbatim)The District Court allowed the case to proceed because the Trustees acted 'under color of' state law for purposes of § 1983.
Key Quotes
Short excerpts from the syllabus in O’Connor-Ratcliff v. Garnier that support the summary and concepts above.
The Trustees initially deleted the Garniers' comments before blocking them from commenting altogether.
The Ninth Circuit affirmed, holding that § 1983's state-action requirement was satisfied because the official 'appearance and content' of the Trustees' pages established a 'close nexus.'
The judgment below is vacated and the case remanded.
