Lindke v. Freed
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Lindke v. Freed 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 Lindke v. Freed.
The Supreme Court reviewed whether James Freed's actions on his Facebook page constituted state action under 42 U.S.C. § 1983, which would implicate First Amendment rights. The Court examined whether Freed acted in his private capacity or as a state official when blocking Kevin Lindke from commenting. The decision focused on whether Freed had actual authority and purported to exercise that authority in his social media posts.
Holding
The single most important “bottom line” of what the Court decided in Lindke v. Freed.
The Court held that a public official engages in state action under § 1983 only if they possess actual authority to speak on the State's behalf and purport to exercise that authority.
Constitutional Concepts
These are the Constitution-related themes that appear in Lindke v. Freed. Click a concept to see other cases that involve the same idea.
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Why Free Speech is relevant to Lindke v. Freed
The case centers on whether Freed's actions on social media violated Lindke's First Amendment rights by blocking him from commenting.
Syllabus excerpt (verbatim)Lindke sued Freed under 42 U. S. C. § 1983, alleging that Freed had violated his First Amendment rights.
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Why State–Federal Power is relevant to Lindke v. Freed
The Court examines whether Freed's actions constituted state action, which is necessary for a § 1983 claim, implicating the allocation of authority between state and private actions.
Syllabus excerpt (verbatim)A public offcial who prevents someone from commenting on the offcial's social-media page engages in state action under § 1983 only if the offcial both (1) possessed actual authority to speak on the State's behalf on a particular matter, and (2) purported to exercise that authority when speaking in the relevant social-media posts.
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Why Procedural Due Process is relevant to Lindke v. Freed
The case involves determining whether Freed's actions deprived Lindke of a federal right under color of state law, which involves procedural due process considerations.
Syllabus excerpt (verbatim)Section 1983 provides a cause of action against '[e]very person who, under color of any statute, ordinance, regulation, custom, or usage, of any State' deprives someone of a federal constitutional or statutory right.
Key Quotes
Short excerpts from the syllabus in Lindke v. Freed that support the summary and concepts above.
A public official who prevents someone from commenting on the official's social-media page engages in state action under § 1983 only if the official both (1) possessed actual authority to speak on the State's behalf on a particular matter, and (2) purported to exercise that authority when speaking in the relevant social-media posts.
The distinction between private conduct and state action turns on substance, not labels.
Lindke's focus on appearance skips over this critical step.
