Robinson v. Hunt County, No. 18-10238 (5th Cir. 2019)Annotate this Case
Plaintiff filed suit against defendants, alleging unconstitutional censorship on the Hunt County Sheriff's Office (HCSO) Facebook page. The Fifth Circuit affirmed the dismissal of plaintiff's claims against the individual defendants because the only claims against the individual defendants were plaintiff's individual-capacity claims for monetary damages and her official-capacity claims for equitable relief, which she did not appeal.
However, the court vacated the dismissal of plaintiff's claims against Hunt County, because plaintiff sufficiently pleaded an official policy of viewpoint discrimination on the HCSO Facebook page. In this case, the complaint alleged that Hunt County had an explicit policy of viewpoint discrimination on the HCSO Facebook page. The court also held that, to the extent the district court determined that plaintiff's declaratory judgment claims against Hunt County were redundant of her claims for injunctive relief, this conclusion was inconsistent with the purposes of the Declaratory Judgment Act and therefore an abuse of discretion. Furthermore, plaintiff's request for declaratory relief was not duplicative of her claims for compensatory damages. Finally, the court vacated the district court's preliminary injunction order and remanded for further proceedings.