Felts v. Green, No. 23-1042 (8th Cir. 2024)
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The United States Court of Appeals for the Eighth Circuit affirmed a lower court's ruling in a case involving Sarah Felts, who had been blocked on Twitter by Lewis E. Reed, the then-President of the St. Louis Board of Aldermen. Felts sued Reed in his official capacity under 42 U.S.C. § 1983, alleging that her First and Fourteenth Amendment rights had been violated. The district court ruled in favor of Felts, granting her declaratory relief, nominal damages, costs, and attorney’s fees. On appeal, the Board’s new President, Megan E. Green, challenged the district court's ruling.
The court held that the act of blocking Felts on Twitter constituted a final municipal policy decision in the area of the City’s business associated with the office of the President of the Board of Aldermen. It also held that Reed administered the account under color of law as an official government account, and that blocking Felts violated her First and Fourteenth Amendment rights. The court further concluded that Reed, as the President of the Board of Aldermen, had the authority to establish the final social media policy for his office and that his decision to block Felts was a deliberate choice of a guiding principle and procedure to silence online critics. Therefore, the City of St. Louis was held liable under 42 U.S.C. § 1983. The court affirmed the district court's judgment granting Felts declaratory relief and nominal damages.
Court Description: [Benton, Author, with Loken and Wollman, Circuit Judges] Civil case - Civil rights. Defendant's predecessor as President of the St. Louis Board of Alderman blocked plaintiff on Twitter, and she sued him in his official capacity for violating her First and Fourteenth Amendment rights. The district court awarded plaintiff declaratory relief, nominal damages, costs and attorney's fees; defendant, the new President, appeals. Held: the former President's unblocking plaintiff after she filed this complaint did not moot the matter; the district court did not err in finding the former President's decision to block plaintiff was a final municipal policy decision in his area of the City's business, the office of President of the Board of Aldermen; the former President administered the account under color of law as an official governmental account; and the former President violated plaintiff's First and Fourteenth Amendment rights.
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