Thomas v. City of Memphis, No. 20-6118 (6th Cir. 2021)
Annotate this Case
Memphis previously maintained an email Media Advisory List to alert members of the media about newsworthy events and activities. The List included Thomas, the founder, editor, and publisher of MLK50: Justice Through Journalism, an online news website covering issues at “the intersection of poverty, power, and public policy.” Thomas claims that in 2018, she was excluded from the List in retaliation for her news coverage of Mayor Strickland. Thomas alleges that she made multiple requests to be returned to the List and that, at one point, the City’s Chief Communications Officer (Madden) stated: “You have demonstrated, particularly on social media, that you are not objective when it comes to Mayor Strickland.”
Thomas’s suit under 42 U.S.C. 1983, asserted violations of the First, Fifth, and Fourteenth Amendments. The district court dismissed Thomas’ claims against Strickland and Madden on other grounds, and later dismissed as moot her claims against the city, finding that the city had ceased relying upon the List to disseminate media advisories and that the process that led to the new media relations policy was “not ad hoc or discretionary.” The Sixth Circuit affirmed. The city demonstrated that there is no reasonable expectation that it will re-implement the List and established that its change in media relations policy completely and irrevocably eradicated the effects of the challenged conduct. The change in media relations policy was “legislative-like.”
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.