Robert Preble and John Casper v. Itasca County Board of Commissioners; John Johnson; Casey Venema; Cory Smith; Terry Snyder; Larry Hopkins; Brett Skyles; Jacob Fauchild; Joe Dasovich; and Austin Rohling

Summary

The United States District Court for the District of Minnesota denied Robert Preble and John Casper’s motion for a preliminary injunction seeking to require Itasca County officials to reinstate an online portal for submitting comments to county board meetings. The court held that plaintiffs had not shown a likelihood of success on their First Amendment retaliation claim because temporal proximity alone did not establish retaliatory motive, and that the remaining preliminary-injunction factors also weighed against relief.

Holdings

1. Plaintiffs were unlikely to succeed on their First Amendment retaliation claim because temporal proximity between protected activity and the alleged retaliatory action, standing alone, did not establish retaliatory motive.
2. The remaining preliminary-injunction factors did not support relief because plaintiffs had not shown infringement of their First Amendment rights or irreparable harm, defendants would be harmed by an injunction concerning conduct not shown to be unlawful, and the public interest did not require restoration of the portal while other channels of communication remained available.

Questions Presented

1. Whether plaintiffs demonstrated a likelihood of success on their First Amendment retaliation claim based primarily on the temporal proximity between filing the lawsuit and the County's closure of the online comment portal.
2. Whether the remaining preliminary-injunction factors supported requiring defendants to reinstate the online comment portal.

Disposition

denied