Carrie Davis v. Colerain Twp., Ohio

CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 20, 2022
Docket21-3723
StatusUnpublished

This text of Carrie Davis v. Colerain Twp., Ohio (Carrie Davis v. Colerain Twp., Ohio) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carrie Davis v. Colerain Twp., Ohio, (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0378n.06

No. 21-3723

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Sep 20, 2022 CARRIE DAVIS, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellant, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE SOUTHERN DISTRICT OF ) OHIO COLERAIN TOWNSHIP, OH, ) ) Defendant-Appellee. )

Before: ROGERS, KETHLEDGE, and MURPHY, Circuit Judges.

MURPHY, J., delivered the opinion of the court in which KETHLEDGE, J., joined, and ROGERS, J., joined in part and in the judgment. ROGERS, J. (pp. 17–18), delivered a separate concurring opinion.

MURPHY, Circuit Judge. Carrie Davis raises weighty First Amendment challenges to two

speech restrictions issued by Colerain Township in southwest Ohio. The first restriction prohibits

the public from posting “inappropriate” or “offensive” comments on the police department’s

Facebook page; the second prohibits the public from making “disrespectful” comments at meetings

of the board of trustees. Davis argues that these restrictions have stifled public debate in a way

that conflicts with Supreme Court precedent. No matter the importance of a legal question,

however, we may not answer it except when necessary to decide a live “Case” or “Controversy”

within the meaning of Article III of the Constitution. And Davis has not raised her free-speech

claims in such a case or controversy. She has failed to show that the Facebook rule has injured

her in the past or is likely to do so in the future. The Township has also repealed the meeting rule. No. 21-3723, Davis v. Colerain Township

So Davis lacks standing to litigate one of her challenges and her other challenge is moot. We thus

affirm the district court’s judgment for the Township, while clarifying that we reject these claims

for lack of jurisdiction and so without prejudice.

I

Davis has not been shy about criticizing the Township’s board of trustees and its police

department. This case highlights two ways in which she has done so—through oral comments at

board meetings and through written comments on the police department’s Facebook page.

Davis regularly speaks during the public-participation portion of board meetings. At one

meeting on an unknown date, Davis recalls that the president of the township’s board chastised

her that she could not speak “disrespectfully” when making comments. Davis Decl., R.19-1,

PageID 67. She did not believe that her criticism had been disrespectful.

At another meeting on April 9, 2019, Davis complained about the board’s hiring of a

finance director. She thought that the board had engaged in cronyism because the chosen candidate

had been a trustee’s friend and neighbor. In the course of her criticism, Davis stated: “[O]ur

firefighters and police officers, they don’t have bachelor’s degrees, but their certifications speak

for themselves too, so you don’t have to have a bachelor’s degree in order to be wholly competent

and qualified for your job.” Davis Dep., R.25-4, PageID 520–21.

About two weeks later, the Chief of the Colerain Police Department, Mark Denney, created

a post on the police department’s Facebook page responding to this comment. Chief Denney

stated: “Recently, a citizen commented that most of our officers do not have college degrees.”

Post, R.25-8, PageID 672. Denney’s post went on to explain that Davis’s claim had been false.

According to Denney, over half of Colerain’s police officers had college degrees, and this

2 No. 21-3723, Davis v. Colerain Township

percentage substantially exceeded the percentage of the general public who held such degrees

(about thirty percent). Id.

Davis did not dispute the accuracy of Denney’s statistics. But she believed that his post

had misrepresented her statement at the board meeting by implying that she had been disparaging

Colerain’s police (rather than its finance director). As Davis explained, she “was actually praising

the police officers and he’s making it appear that I am criticizing them.” Davis Dep., R.25-4,

PageID 508. Some people even wrote comments on Denney’s post ridiculing the “citizen” who

had made the statement, which confirms that it could be read in the way that Davis did.

To clarify matters, Davis alleges, she did two things. She both added a comment to

Denney’s post describing why his allegation had been misleading and attached a video of her board

presentation to prove the point. After Davis uploaded this video, it allegedly received “likes” from

members of the public. The next day, though, Davis noticed that someone had removed her

comment and video from the comments section of Denney’s post. (According to Denney, the

Facebook page’s settings made it impossible for a commenter like Davis to include videos with

comments, but we must construe the facts in Davis’s favor at this stage.)

Without the video to provide context, members of the public continued to criticize the

“citizen” who had made the college-degree statement about the police. Davis repeatedly replied

to these commenters that Chief Denney’s post was inaccurate. As one example, she told a person:

“this was never said. I posted the video here but the chief hid it so people can’t see for themselves.

It is on my page and public. I deserve an apology because he is going around claiming I said this

and the video shows I did not.” Comment, R.25-9, PageID 675. Nobody removed Davis’s replies

to these commenters.

3 No. 21-3723, Davis v. Colerain Township

Yet the purported deletion of Davis’s video was the last straw for her. In June 2019, she

sued Colerain Township under 42 U.S.C. § 1983 alleging that it had violated the First

Amendment’s Free Speech Clause in several ways. As relevant now, Davis alleged two facial

challenges and one as-applied challenge.

Davis first asserted a facial constitutional challenge to one of the Township’s rules

regulating public statements at board meetings. First passed in 2010, these rules originally noted

that “condescending comments” “would not be tolerated” and that speakers should show “respect”

to the board. 2010 Rules, R.29-1, PageID 720. The Township updated the rules in 2020. The

new version included a similar regulation that we will call the “Meeting Rule”: “The use of

profane, disrespectful or threatening language or gestures will not be tolerated.” 2020 Rules, R.29-

1, PageID 726. In an amended complaint, Davis alleged that the Meeting Rule’s ban on

“disrespectful” speech violated the First Amendment by discriminating against speech based on

the speaker’s viewpoint. Cf. Matal v. Tam, 137 S. Ct. 1744, 1763 (2017) (plurality opinion).

Davis next asserted a facial constitutional challenge to one of the police department’s rules

regulating the comments that the public could make on its Facebook page. In this provision (which

we will call the “Facebook Rule”), the police department “reserve[d] the right to remove any

comments/reviews that are inappropriate or offensive, including comments that” express “racism,

hatred, slander, threats, obscenity, violence, [or] vulgarity[.]” Facebook Rules, R.24-2, PageID

382. Davis’s amended complaint suggested that this speech restriction likewise violated the First

Amendment by engaging in viewpoint discrimination. Cf. Iancu v. Brunetti, 139 S. Ct. 2294,

2298–300 (2019).

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Carrie Davis v. Colerain Twp., Ohio, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carrie-davis-v-colerain-twp-ohio-ca6-2022.