Scaer v. City of Nashua, NH

CourtCourt of Appeals for the First Circuit
DecidedDecember 22, 2025
Docket25-1356
StatusPublished

This text of Scaer v. City of Nashua, NH (Scaer v. City of Nashua, NH) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scaer v. City of Nashua, NH, (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 25-1356

STEPHEN SCAER; BETHANY R. SCAER,

Plaintiffs, Appellants,

v.

CITY OF NASHUA, NEW HAMPSHIRE,

Defendant, Appellee,

JAMES W. DONCHESS, Mayor, City of Nashua, New Hampshire; JENNIFER L. DESHAIES, Risk Manager, City of Nashua, New Hampshire,

Defendants.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

[Hon. Landya B. McCafferty, U.S. District Judge]

Before

Gelpí, Lynch, and Howard, Circuit Judges.

Nathan J. Ristuccia, with whom Roy S. McCandless, Roy S. McCandless, Esq., PLLC, Endel Kolde, and Institute for Free Speech were on brief, for appellants.

Steven A. Bolton, with whom Jonathan A. Barnes, City of Nashua, Office of Corporation Counsel, was on brief, for appellee. December 22, 2025 LYNCH, Circuit Judge. In this appeal by two Nashua, New

Hampshire citizens from the denial of their motion for a

preliminary injunction, the City of Nashua concedes that if the

City's decision not to allow these two citizens' requests to fly

flags on a "Citizen Flag Pole" on City Hall Plaza was not

government speech, then the City has engaged in impermissible

viewpoint discrimination under the First Amendment. We hold that

the district court erred in concluding that the City had engaged

in government speech. Under the test defining government speech

outlined in Shurtleff v. City of Boston, 596 U.S. 243 (2022),

Nashua during the time period at issue was not engaged in

government speech as to the Citizen Flag Pole. We also conclude,

as appellants conceded at oral argument, that interim declaratory

relief in appellants' favor suffices to remedy the violation.

I.

A.

For purposes of this appeal, the material facts are not

in dispute.

The current Nashua City Hall was built in 1939. On City

Hall Plaza, the government property outside of City Hall that is

open to the public, there are four flagpoles of varying heights.

Until 2017, Nashua exercised exclusive control over the flags flown

on the poles, choosing to display only government flags such as

the American flag and the New Hampshire state flag. The City

- 3 - continues to exercise such control over three of the flagpoles.

In 2017, after the election of Mayor James W. Donchess,1 who has

since been reelected to that position, Nashua created what it

called the "Citizen Flag Pole" as to one of the poles.2

The City's website, under the headings "Citizen Flag

Pole" and "Fly a Flag," provided a statement, which in total read:

A pole in front of City Hall is reserved for the citizens of Nashua to fly a flag in support of their cultural heritage, observe an anniversary or honor a special accomplishment. Any group wishing to fly a flag must provide the flag.

The website provided no other written guidance describing the

program and directed interested parties to contact Nashua's Risk

Management Office for further information.

Private citizens and groups interested in flying a flag

on the Citizen Flag Pole were required to submit to the City's

Risk Manager a Special Events Application, which in turn required

them to request specific dates to fly a flag and also to confirm

that they would abide by local ordinances and agree to indemnify

the City for any damages caused by their flag raising event. The

record does not reflect any substantive review by the Risk Manager

1 Donchess previously served two terms as Nashua's mayor from 1984 to 1991. As the City has acknowledged, "[t]he Mayor's office has always been in control of the policies concerning the flag[s]." 2 Nashua did not use the name "Citizen Flag Pole" in the 2022 Flag Policy we describe later but recognizes that City officials continued to use the name, and the record reflects that members of the public did so as well. We use that descriptive term here.

- 4 - but describes her role as ensuring that no two groups reserved the

Citizen Flag Pole for the same period.

If the City did not own a proposed flag, applicants

supplied their own flags, which remained their property while

displayed on the Citizen Flag Pole. Applicants usually raised the

flags themselves, using a tool borrowed from the City. Ordinarily,

Nashua allowed approved flags to fly for approximately one week,

after which time applicants were expected to retrieve their flags.

Roughly ten flags were flown on the Citizen Flag Pole each year.3

Many of the flag raisings were accompanied by a short, privately

organized ceremony on City Hall Plaza, sometimes attended by local

elected officials but often without any City representatives

present. Applicants who planned a ceremony were required to

provide additional details in their Special Events Application

about the expected attendance and any anticipated sidewalk

obstruction.

Appellants Stephen and Bethany Scaer have resided in

Nashua for three decades. Beginning in 2017, Bethany submitted

3 Groups of private citizens regularly flew flags on the Citizen Flag Pole to commemorate Pride Month, Indian Independence Day, Brazilian Independence Day, Greek Independence Day, International Francophonie Day (celebrating the French language and Francophone culture), and the anniversary of the founding of Nashua's Lions Club. Other flags flown once or on occasion included the Kurdistan flag, the Christian flag, the Lutheran flag, the Porcupine flag (described later), and flags supporting National Recovery Month and organ donation awareness.

- 5 - and received approval for several applications to use the Citizen

Flag Pole, including for flying the Luther Rose flag in honor of

the 500th anniversary of the Protestant Reformation, the Lutheran

flag, and a flag commemorating the ratification of the Nineteenth

Amendment. For each approved request, Bethany supplied and raised

the flag herself and organized a small flag raising ceremony not

attended by any City officials.

Nashua initially approved Bethany's application to fly

a "Save Women's Sports" flag, which the Scaers raised on October

10, 2020. The Scaers explain that the flag expresses their belief

"that women have inalienable rights based on their biological sex

that governments have a duty to protect and that allowing

biological males to compete against women in sports denies women

their rights and the equality due them under both the U.S.

Constitution and Title IX."4 One day after the flag's raising,

and after the City received complaints that the flag was

transphobic, Nashua reversed its approval, revoked permission, and

In July 2024, following public and legislative debate over 4

transgender students' participation in athletics, New Hampshire enacted House Bill 1205, which requires participants on interscholastic sports teams to have the same biological sex at birth. See N.H. Rev. Stat. Ann. § 193:41. In September 2024, a federal district court preliminarily enjoined enforcement of HB 1205 as applied to two transgender students, finding that they were likely to succeed on their Equal Protection and Title IX claims. See Tirrell v. Edelblut, 748 F. Supp. 3d 19, 41, 47 (D.N.H. 2024). The litigation has not quelled public debate about transgender athletic participation in New Hampshire schools.

- 6 - removed the flag from the Citizen Flag Pole. Bethany appealed the

decision to Mayor Donchess, who denied the appeal.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cox v. Louisiana
379 U.S. 536 (Supreme Court, 1965)
Forsyth County v. Nationalist Movement
505 U.S. 123 (Supreme Court, 1992)
Ashcroft v. American Civil Liberties Union
542 U.S. 656 (Supreme Court, 2004)
Pleasant Grove City v. Summum
555 U.S. 460 (Supreme Court, 2009)
Sutliffe v. Epping School District
584 F.3d 314 (First Circuit, 2009)
Matal v. Tam
582 U.S. 218 (Supreme Court, 2017)
Pereira Brito v. Garland
22 F.4th 240 (First Circuit, 2021)
United States v. Donald Trump
88 F.4th 990 (D.C. Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Scaer v. City of Nashua, NH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scaer-v-city-of-nashua-nh-ca1-2025.