Carey v. Throwe, No. 19-1194 (4th Cir. 2020)
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Plaintiff filed suit against defendants after he was terminated for submitting two blog posts about the then Captain of the Internal Affairs Unit of the Maryland Natural Resources Police (MNRP). Among other things, the blog posts contained screenshots from the Captain's private Facebook page that showed photos of the Captain posing with scantily-clad women and various comments that he had made about gun violence.
The Fourth Circuit affirmed the dismissal of plaintiff's First Amendment retaliation claim, holding that plaintiff's posts concern nothing more than purely personal speech, as they are devoid of any content that rises to a level of public concern. The court also affirmed the district court's dismissal of plaintiff's claim that defendants violated plaintiff's right to carry a concealed firearm under the Law Enforcement Officer Safety Act, holding that the Act was not privately enforceable under 42 U.S.C. 1983. Finally, the court affirmed the dismissal of plaintiff's defamation per se claim, holding that the statement at issue was not actionable as defamation.
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