Richard Fitzgerald v. City of Fresno, et al.

CourtDistrict Court, E.D. California
DecidedApril 20, 2026
Docket1:21-cv-01409
StatusUnknown

This text of Richard Fitzgerald v. City of Fresno, et al. (Richard Fitzgerald v. City of Fresno, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Fitzgerald v. City of Fresno, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 RICHARD FITZGERALD, Case No. 1:21-cv-01409 JLT SAB

12 Plaintiff, ORDER GRANTING MOTIONS FOR SUMMARY JUDGMENT IN PART 13 v. (Docs. 33, 34) 14 CITY OF FRESNO, et al., 15 Defendants. 16 17 Richard Fitzgerald was terminated from his position as a police officer in the Fresno 18 Police Department in April 2021. This was just a few weeks after the results of the 2020 19 presidential election sparked widespread and often violent protests, including the January 6 riot 20 inside and around the United States Capitol Building. Fitzgerald was terminated because an 21 internal investigation revealed that he had recently been a member of the Proud Boys, had 22 supported the use of violence against political protesters on his social media accounts, and had 23 been involved in a violent scrum at a political rally in Sacramento. He alleges in this case that he 24 was terminated without due process and in retaliation for his political speech and choices of 25 associates, citing the First and Fourteenth Amendments, and he makes other claims under state 26 law. 27 The City of Fresno and three of its officials (the Mayor, the City Manager, and the Police 28 Chief) move for partial summary judgment of Fitzgerald’s federal claims against them. Those 1 motions are GRANTED IN PART, as explained in this order: (1) the City’s liability cannot be 2 adjudicated at this stage, but it has demonstrated that Fitzgerald’s damages will be limited in 3 some respects; (2) the Police Chief and City Manager are entitled to qualified immunity; and 4 (3) Fitzgerald has not cited evidence that could establish the Mayor’s liability under 42 U.S.C. 5 § 1983. 6 BACKGROUND 7 Fitzgerald began working as a Police Officer for the City more than twenty years ago, in 8 2003. (Doc. 37-6 at 31.) In early 2020, he joined the Fresno Chapter of the Proud Boys. (Docs. 9 37-6 at 32; 34-3 at 175.) The Proud Boys are now infamous for the role that some of them played 10 in the riot inside and around the U.S. Capitol building on January 6, 2021. See, e.g., United 11 States v. Tarrio, 605 F. Supp. 3d 73, 78–82 (D.D.C. 2022); United States v. Pezzola, 531 F. Supp. 12 3d 139, 142 (D.D.C. 2021); United States v. Chrestman, 525 F. Supp. 3d 14, 19 (D.D.C. 2021). 13 By early 2021, many people and organizations had come to regard the Proud Boys as a “hate 14 group, a criminal group, or a racist group,” including Fresno’s own Chief of Police. (See Doc. 15 34-3 at 564–66.) But the group was founded several years before 2021, and it was controversial 16 even before Fitzgerald joined, when it was less well known. See, e.g., McInnes v. S. Poverty L. 17 Ctr., Inc., 811 F. Supp. 3d 1319, 1325 (M.D. Ala. 2025). 18 Fitzgerald first heard about the Proud Boys from an interview with one of its leaders. 19 (Doc. 34-3 at 175.) After “some research” and “deeper digging,” Fitzgerald came to believe that 20 the group was “basically just a men’s fraternity” (id.), not a racist, sexist, or homophobic 21 organization, as some had portrayed it (id. at 176–77). When he joined the Proud Boys, the 22 initiation process was uncomplicated, essentially the recitation of an oral oath, “[s]omething 23 about being a proud western chauvinist and you’re not going to apologize for creating the modern 24 world.” (Id. at 177.) He went to meetings and events, wore clothes and colors associated with 25 the Proud Boys, got a Proud Boys tattoo, and began using the moniker “Sheepdog.” (Doc. 37-6 at 26 32.) He later claimed that he “got into leadership” as well. (Doc. 34-3 at 661.) His involvement 27 made him a “third degree” member; the fourth degree is highest. (Id. at 183–84.) As Fitzgerald 28 understood it, a member could achieve the fourth degree by acting “in self-defense of others or by 1 extended acts of charity.” (Id.) 2 With the exception of one other officer, also Proud Boys member, Fitzgerald did not 3 reveal his Proud Boys membership to his superiors, nor to his fellow officers. (Id. at 177, 183, 4 193.) He did, however, advertise his status as a Proud Boy on several ostensibly anonymous 5 social media accounts, where he also advocated political violence and invited California residents 6 to contact him and join the Proud Boys. (Id. at 656.) “Fight antifa?” he asked on one account. 7 “I’m your huckleberry.”1 (Id. at 656–57.) In another, he wrote that “Civil War 2” had started and 8 that it was time to “step up.” (Id. at 658.) In another, he posted a picture of a t-shirt bearing the 9 slogan “I love my country fight me” and lamented in the caption that he was “[s]till looking for 10 takers.” (Id. at 659.) In yet another, he posted a picture of a shoe with Proud Boys branding and 11 wrote in the caption, “I’ve been told if you kick antifa with these on, they bleed just a little more.” 12 (Id. at 653, 654.) 13 Fitzgerald created similarly provocative content before he joined the Proud Boys as well. 14 For example, he once posted a picture of a bloody fist with the caption “Rough day at work.” (Id. 15 at 655) He also posted pictures of himself in a “Punisher” costume. (Id. at 651–52.) Fitzgerald 16 explained in his deposition that to him, the Punisher is a comic book character, a former marine, a 17 vigilante who uses “weapons and stuff” to avenge the death of his family at the hands of a gang. 18 (Doc. 34-3 at 168–69.) To others, the Punisher is an antihero who has sunken to fighting crime 19 with murder, threats, and extortion. See, e.g., Garza v. City of Donna, 922 F.3d 626, 633 (5th Cir. 20 2019) (citing Sitzes v. City of West Memphis, Ark., 606 F.3d 461, 472 n.9 (8th Cir. 2010) (Lange, 21 J., dissenting)). One of the captions Fitzgerald attached to his photos fit that theme. He wrote 22 that “shit is a lot easier when you can kill people,” a Punisher quote, as a caption for a picture of 23 himself in a Punisher costume, aiming a rifle. (Doc. 34-3 at 651.) In his deposition, Fitzgerald 24 dismissed these pictures and quotes as innocuous cosplay in support of a charitable endeavor. 25 (Doc. 34-3 at 168–69.) 26 In November 2020, Fitzgerald and several other Proud Boys members and “prospects” 27 (that is, potential members) went to the “Stop the Steal” political rally in Sacramento. (Doc. 37-6

28 1 at 33.) He wore a mask, the Proud Boys’ colors (black and yellow), and a tactical vest bearing his 2 Proud Boys moniker, “Sheepdog.” (Id.; see also, e.g., Doc. 34-3 at 259–76.) At one point, he 3 was captured on video in the midst of a violent scuffle between two opposing groups of 4 protesters, his hands on a rainbow-colored flag, apparently pulling at it as though he was trying to 5 take it from the woman who was holding it. (See id. at 347–52.2) He explained in his deposition 6 that he was trying to prevent her from hitting him with it. (Doc. 34-3 at 189.) Whatever his 7 intentions, a group of several other protesters began punching and kicking the woman almost 8 immediately after Fitzgerald laid hands on her flag, and they eventually took the flag from her. 9 (See id.) Another man, a Proud Boys prospect named Brian who had come up to Sacramento 10 with Fitzgerald, then handed him the flag, and he cast it aside. (See id. at 189.) 11 Fitzgerald says he saw criminal conduct on “both sides” at the rally. (Doc. 34-3 at 181.) 12 He did not report anything to his superiors or discuss what he had seen with any other authorities, 13 such as the Sacramento Police Department officers on the scene, but he did decide that he had 14 seen enough; he resigned from the Proud Boys the next day. (Id. at 178.) As he explained in his 15 deposition, he was more interested in giving “back to the community” than the Proud Boys 16 seemed to be.

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Richard Fitzgerald v. City of Fresno, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-fitzgerald-v-city-of-fresno-et-al-caed-2026.