Stephen P. Stubbs v. Clearwater County, a political subdivision; Chris Goetz, in his official capacity as Clearwater County Sheriff; and John Does I-X

Summary

The United States District Court for the District of Idaho granted Clearwater County’s motion for reconsideration and motion for summary judgment in a § 1983 action concerning a sheriff’s Facebook activity. Applying Lindke v. Freed, the court held that the sheriff’s disclaimer created a heavy presumption that his social-media activity was private and that the plaintiff had not shown state action sufficient to support a Monell claim. The court also dismissed the claims against the unidentified John Doe defendants.

Holdings

1. Lindke v. Freed constituted an intervening change in controlling law because the court's prior application of the nexus test from Garnier was irreconcilable with Lindke's framework for determining when a public official's social-media activity constitutes state action.
2. Sheriff Goetz's Facebook activity was private conduct, not state action, because the page's disclaimer created a heavy presumption of personal activity and Stubbs's evidence did not rebut that presumption.
3. Clearwater County was entitled to summary judgment because, absent state action and an underlying constitutional violation, Stubbs could not establish the constitutional-violation element of his municipal-liability claim.
4. The claims against John Does I-X were dismissed because Stubbs had not amended the complaint to identify the anonymous defendants despite having more than three years to do so.

Questions Presented

1. Whether the Supreme Court's decision in Lindke v. Freed constituted an intervening change in controlling law warranting reconsideration of the court's prior interlocutory denial of Clearwater County's motion for summary judgment.
2. Whether, under Lindke, Sheriff Goetz's Facebook activity constituted state action when the page contained a disclaimer identifying it as personal and nonofficial, and the post concerned information about a police-involved shooting that had already been sent to the media.
3. Whether Stubbs could establish the constitutional-violation element necessary to maintain a Monell municipal-liability claim against Clearwater County.
4. Whether the claims against the unidentified John Doe defendants should be dismissed because Stubbs had not identified or substituted those defendants.

Disposition

other