Mackenzie Elaine Brown v. Robert Jordan Warren, et al.

Summary

The United States District Court for the Western District of North Carolina ruled on Defendants’ Motion for Partial Summary Judgment in Mackenzie Elaine Brown’s civil rights action. The court granted summary judgment on the equal protection and civil conspiracy claims and on the First Amendment retaliation claim against Defendant Reece, but denied summary judgment on the retaliation claim against Defendant Maybin, concluding that Maybin was not entitled to qualified immunity. The case was ordered to proceed to trial on the remaining First Amendment retaliation claims.

Holdings

1. Defendant Reece is entitled to summary judgment because no reasonable jury could find sufficient facts to establish the adverse action or causation elements; the $550 fine did not constitute an adverse action and the implicit threat was empty.
2. Summary judgment is denied; a reasonable jury could find sufficient facts to establish each element of the First Amendment retaliation claim against Maybin, and Maybin is not entitled to qualified immunity because the right was clearly established.
3. The equal protection claims are dismissed against all Defendants because they merely repackage the First Amendment retaliation claims and thus fail to state a separate claim under the Equal Protection Clause.
4. The intracorporate conspiracy doctrine bars the civil conspiracy claims against the Henderson County Sheriff's Office employees because there is no evidence any defendant had an independent personal stake.

Questions Presented

1. Whether Defendant Reece is entitled to summary judgment on the First Amendment retaliation claim.
2. Whether Defendant Maybin is entitled to summary judgment or qualified immunity on the First Amendment retaliation claim.
3. Whether all Defendants are entitled to summary judgment on the Fourteenth Amendment equal protection claims.
4. Whether all Defendants are entitled to summary judgment on the civil conspiracy claims.

Disposition

The Defendants' Motion for Partial Summary Judgment is granted in part and denied in part. Summary judgment is granted on the First Amendment retaliation claim against Reece, the Equal Protection claims against all Defendants, and the Civil Conspiracy claims against all Defendants. Summary judgment is denied on the First Amendment retaliation claim against Maybin. The case proceeds on the First Amendment retaliation claims against Warren, Landers, Lindsay, and Maybin.