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Archive for the ‘Civil Rights – Section 1983’ Category

Cancelled: April 23-24, 2020, Conference on Section 1983

It took a virus to cancel the previously scheduled 37th Conference on Section 1983 in Chicago, and to stop our streak at 36 consecutive years.

This Conference, with an outstanding group of speakers, was to be held on April 23-24, 2020, at Chicago-Kent College of Law. Regrettably, we had no choice but to cancel because of the corona-virus pandemic.

We fully expect the 37th annual conference to be held in April 2021 (the precise dates have not yet been determined). All of our dedicated speakers have already committed to participate next year. So I can promise you that the 2021 Conference will be better than ever.

If you have any questions, you may contact either our CLE department at cle.kentlaw.iit.edu or me at snahmod@kentlaw.edu.

In the meantime, stay safe.

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Written by snahmod

March 20, 2020 at 10:32 pm

Takings Claims Against States After Knick: Some Unanswered Questions

The Knick takings decision

The Supreme Court, in Knick v. Township of Scott, 139 S. Ct. 2162 (2019), a game-changing 5-4 takings decision, overruled Williamson County Regional Planning Comm’n v. Hamilton Bank, 473 U.S. 172 (1985). In Knick, the district court had dismissed a property owner’s section 1983 takings claim for damages against a local government because she had not pursued an inverse condemnation action in state court against the local government as required by Williamson County. The Court, reversing in an opinion by Chief Justice Roberts, declared:

We now conclude that the state-litigation requirement imposes an unjustifiable burden on takings plaintiffs, conflicts with rest of our takings jurisprudence, and must be overruled. A property owner has an actionable Fifth Amendment takings claims when the government takes his property without paying for it. … [This means] that the property owner has suffered a violation of his Fifth Amendment rights when the government takes his property without just compensation, and may therefore bring his claim in federal court under [section] 1983 at that time.

(Knick, its relation to Williamson County and its implications for section 1983 damages actions claiming takings against local governments are addressed at length in a previous post here: https://nahmodlaw.com/2019/07/25/the-knick-case-takings-and-section-1983-a-somewhat-different-view/).

What are the implications for section 1983 damages actions claiming takings against states?

Even after Knick, a section 1983 takings plaintiff attempting to sue a state for damages in federal court has to confront two obstacles. The first is the Supreme Court’s decision in Will v. Michigan Dept. of State Police, 491 U.S. 58 (1989), that a state, unlike a local government, is not a suable “person” within the meaning of section 1983. And second, even apart from Will, the Eleventh Amendment would serve as a bar to such a federal court lawsuit since Will also held that section 1983 did not abrogate Eleventh Amendment immunity.

A section 1983 takings plaintiff who sues a state for damages in state court in order to avoid the Eleventh Amendment bar would fare no better because, as mentioned, a state is not a suable “person” for section 1983 purposes as a matter of statutory interpretation. A state thus cannot be sued for damages under section 1983 anywhere.

The result is that the section 1983 takings plaintiff suing a state in federal court has to forego his or her damages claim and instead seek declaratory and injunctive relief under section 1983 against the relevant state officials alleging an unconstitutional taking. If successful, the plaintiff would be entitled to attorney’s fees in addition to prospective relief.

In addition, the section 1983 plaintiff seeking damages for an unconstitutional taking could sue state officials in their individual capacities for damages. In many such cases, though, these state officials would likely defend on the ground of absolute quasi-judicial immunity and, as a fallback, on the ground of qualified immunity, arguing that they did not violate clearly settled takings law.

Here is where it gets interesting.

Could a takings plaintiff seeking damages against a state in federal court not use section 1983 but instead rely on the Fourteenth Amendment (which incorporates the Fifth) as the basis for his or her claim? Notice that the section 1983 “person” issue drops out. You may say that there is still a potential Eleventh Amendment problem. But could the Fourteenth Amendment takings plaintiff plausibly make two related arguments. First, that the Fourteenth (and Fifth) Amendments are self-executing, per Knick, and give rise on their own to potential damages liability where there has been a taking without just compensation? And second, that the Fourteenth (and Fifth) Amendments, by virtue of their self-executing nature regarding just compensation (this is where Knick comes in again), abrogate Eleventh Amendment immunity? The Fourteenth Amendment, at least insofar as takings are concerned, could be read as modifying the Eleventh Amendment in this respect.

A related question, whose answer might be relevant to the above questions about states, is whether any of this reasoning applies to Fifth Amendment damages taking claims against the federal government. Is the Fifth Amendment self-executing in this respect and does it abrogate federal sovereign immunity? Or has the federal government separately waived its sovereign immunity under the Tucker Act, 28 U.S.C. section 1491(a)(1), thus avoiding the need to answer the abrogation question?

There you have it. Please feel free to email me at snahmod@kentlaw.edu with any thoughts you may have.

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Written by snahmod

January 31, 2020 at 6:24 pm

Upcoming 37th Conference on Section 1983: April 23-24, 2020

I am pleased to announce that the 37th consecutive Conference on Section 1983 will be held at Chicago-Kent College of Law on Thursday and Friday, April 23-24, 2020.

As always, the Conference features outstanding and experienced scholars and practitioners addressing virtually all aspects of section 1983 and related constitutional provisions. The Conference also includes updates on important recent and forthcoming Supreme Court cases and on attorney’s fees and related ethical issues. In addition, this year we have new presentations on due process, immigration and takings law after Knick.

Here is the registration link: https://cle.kentlaw.edu/conference-detail.asp?productId=426.

Please call our CLE office, 312-906-5090, or connect with the office via email, cle@kentlaw.iit.edu, if you have any questions.

Or, you may email me directly at snahmod@kentlaw.edu.

Here is a chronological listing of each day’s presentations.

Day 1: Thursday, April 23, 2020

Sheldon Nahmod on the basics of the section 1983 claim

Erwin Chemerinsky on individual immunities

Karen Blum on municipal liability

Rosalie Levinson on due process

Erwin Chemerinsky on the Supreme Court’s current and forthcoming Terms

Day 2: Friday, April 24, 2020

John Murphy on practical considerations in section 1983 litigation

Kimberly Bailey on the Fourth Amendment

John Murphy on takings after Knick (concurrent session)

Victoria Carmona on immigration law and section 1983 (concurrent session)

Gerry Birnberg on attorney’s fees and ethical issues

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I hope to see you there. And if you do attend, please say hello.

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Written by snahmod

January 15, 2020 at 9:10 am

A Section 1983 Primer (13): Qualified Immunity

The Background

I have posted previously about absolute immunity, including legislative and judicial immunity. As discussed in those posts, absolute immunity from section 1983 damages liability is intended to protect certain persons who engage in allegedly unconstitutional legislative, judicial and prosecutorial conduct from not only liability but from the very costs of defending.

(see https://nahmodlaw.com/2012/10/25/a-section-1983-primer-7-introduction-to-absolute-individual-immunity/; https://nahmodlaw.com/2013/02/20/a-section-1983-primer-8-absolute-legislative-immunity/; https://nahmodlaw.com/2013/03/14/a-section-1983-primer-9-absolute-judicial-immunity/)

In contrast, qualified immunity from section 1983 damages liability (which covers state and local government officials who are not protected by absolute immunity) is intended primarily to protect these officials from liability itself. However, over the years the Supreme Court has increasingly broadened the scope of qualified immunity so that it often functions like absolute immunity to protect state and local government officials even from the costs of defending.

The Basics

Qualified immunity is an affirmative defense and so it must be raised by the defense. It becomes relevant when state or local government officials are sued in their individual capacities for damages. It once had both a subjective component–actual knowledge– and an objective component–the duty to know clearly settled law. See Wood v. Strickland, 420 U.S. 308 (1975). However, in a game-changing decision, the Supreme Court eliminated the subjective part, with the result that qualified immunity is now objective in nature. Harlow v. Fitzgerald,  457 U.S. 800 (1982).

In Harlow and other cases, the Court has emphasized that the qualified immunity determination is for the district court and should be made as quickly as possible, even before discovery. This change was intended by the Court, as a matter of policy, to protect government officials from “insubstantial” claims and thereby minimize the costs of defending.

The qualified immunity inquiry is as follows: as of the time of the challenged conduct, and under the circumstances facing the defendant, would a reasonable official have believed that he or she was violating clearly settled law.

This inquiry is, as noted, made as of the time of the challenged conduct (and is therefore backward-looking), while the constitutional merits of the section 1983 claim itself are decided under current constitutional standards. The Court has since emphasized that the clearly settled law inquiry should be made at a fairly fact-specific level because “fair notice” is what is required. Anderson v. Creighton, 107 S. Ct. 3034 (1987).

However, a case on all fours is not required for a finding of a violation of clearly settled law. Some conduct can be so obviously unconstitutional when it occurred that even without a comparable precedent, the government official violated clearly settled law. Hope v. Pelzer, 122 S. Ct. 2508 (2002). On the other hand, in the past decade and a half, the Court, particularly in law enforcement cases, has taken a much more pro-defendant position on qualified immunity, instructing courts not to make the clearly settled law inquiry at too general a level. For example, see: https://nahmodlaw.com/2019/03/04/city-of-escondido-v-emmons-another-scotus-summary-reversal-in-a-qualified-immunity-excessive-force-case/.

Whose decisions constitute clearly settled law? At the top of the list is a relevant Supreme Court decision. Next is a relevant decision of the particular circuit court of appeals (district court decisions are not clearly settled law although they may be evidence of it). Next is a strong consensus in the circuits. And although I have never seen this, it is even possible that a state Supreme Court decision on the relevant federal constitutional issue could constitute clearly settled law as well.

The qualified immunity inquiry is primarily for the trial judge. The jury should not be instructed about qualified immunity, although the jury’s findings of fact may be relevant to the qualified immunity outcome. Hunter v. Bryant, 112 S. Ct. 534 (1992). And while it is better for the development of constitutional law that the trial judge decide the constitutional merits before deciding qualified immunity, that is not mandatory. Pearson v. Callahan, 129 S. Ct. 534 (1992).

Finally, district court denials of qualified immunity based on the clearly settled law determination (and not on factual disputes) may be appealed immediately by government officials to the circuit court of appeals. See Mitchell v. Forsyth, 105 S. Ct. 2806 (1985) and Johnson v. Jones, 115 S. Ct. 2151 (1995).

On qualified immunity generally, see ch. 8 in Nahmod, CIVIL RIGHTS AND CIVIL LIBERTIES LITIGATION: THE LAW OF SECTION 1983 (2019)(West & Westlaw). You might also want to search “qualified immunity” on this blog for additional discussions of qualified immunity decisions.

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Written by snahmod

October 7, 2019 at 9:35 am

The Intersection of Rehberg (Absolute Witness Immunity) and Section 1983 Malicious Prosecution

What is the relation between allegedly false grand jury testimony by a police officer (protected by absolute witness immunity) followed by an indictment (thereby establishing probable cause) and a section 1983 malicious prosecution claim, one of whose elements is the absence of probable cause?

(see generally, Nahmod, CIVIL RIGHTS AND CIVIL LIBERTIES LITIGATION: THE LAW OF SECTION 1983 (2019), ch. 3 on section 1983 malicious prosecution and ch. 7 on witness immunity).

The Sixth Circuit has worked through, and clarified, this relation is a series of such cases.

Sanders v. Jones

The first such case, Sanders v. Jones, 845 F.3d 721 (6th Cir. 2017), as amended on denial of reh’g, en banc (Mar. 20, 2017), involved a claim against a police officer who allegedly gave false grand jury testimony identifying the plaintiff as the person who sold illegal drugs to a confidential informant. The officer moved for summary judgment based in part on absolute immunity.

Ruling in the officer’s favor on this issue, the Sixth Circuit observed that this “defense presents a question of first impression about how the Supreme Court’s provision of absolute immunity for grand jury witnesses in Rehberg v. Paulk, 566 U.S. 356 (2012), intersects with the Sixth Circuit’s requirements for malicious prosecution claims where a grand jury indicted the plaintiff.” The court concluded that Rehberg’s absolute immunity for grand jury testimony precluded the plaintiff’s claim because “she cannot rebut the indictment’s presumption of probable cause without using [defendant]’s grand jury testimony.”

King v. Harwood

Thereafter, the Sixth Circuit, in King v. Harwood, 852 F.3d 568 (6th Cir. 2017), somewhat more narrowly described the intersection of Rehberg and Sanders as follows:

Thus, while Sanders may control the outcome of many [section 1983] malicious-prosecution cases in which the sole or primary act of the defendant law-enforcement officer is delivering grand-jury testimony, Sanders does not control our decision here. … Rehberg does not afford [defendant] absolute immunity for his actions that are prior to, and independent of, his grand-jury testimony. And because [plaintiff] has alleged that [defendant] set her prosecution in motion [by seeking warrants “despite the absence of probable cause and making knowing or reckless false statements implicating plaintiff in his investigative report”] … [plaintiff] may properly base her malicious-prosecution claim on those actions by [defendant] without triggering the absolute immunity established by Rehberg.

Miller v. Maddox

Following King, the Sixth Circuit reversed the district court’s grant of summary judgment against the plaintiff who had filed a section 1983 Fourth Amendment malicious prosecution claim against an officer. The officer allegedly made false statements that resulted in plaintiff’s arrest, charges and indictment for reckless driving and resisting arrest. The court ruled that the plaintiff could establish an exception to the general rule that the issuance of an indictment conclusively establishes probable cause. First, the officer initiated the criminal prosecution because, even though he did not speak directly with the prosecutor, he swore out a warrant affidavit submitted to the night commissioner and was the only witness to testify in the preliminary hearing. Second, the King exception to the general rule applied to create a “mere rebuttable presumption of probable cause.” So the plaintiff was entitled to rebut that presumption: the false statements were material to plaintiff’s prosecution because there was no other evidence that would have allowed the charges to proceed to the grand jury otherwise, and the defendant’s false statements were apparently not used during the grand jury proceedings. Miller v. Maddox, 866 F.3d 386 (6th Cir. 2017).

Mills v. Barnard

Finally, in Mills v. Barnard, 869 F.3d 473, 480 (6th Cir. 2017), reh’g en banc denied, 10-12-17, the Sixth Circuit used King to point out that “[t]he existence of an indictment is thus not a talisman that always wards off a malicious-prosecution claim.” Here, a post-indictment DNA report that could have exculpated the plaintiff was the “linchpin of the prosecution’s probable cause” for the continuing detention of the plaintiff. Judge Griffin dissented, 869 F.3d at 487, arguing on various grounds that the district court properly dismissed the plaintiff’s section 1983 Fourth Amendment malicious prosecution claim.

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Written by snahmod

September 23, 2019 at 8:49 am

A Conscious Decision Not To Do Something Can Be An Actionable Official Policy or Custom Under Section 1983

We all know that a local government can be held liable for damages under section 1983 when its official policy or custom brings about a constitutional deprivation. Monell v. Dept. of Social Services,  436 U.S. 658 (1978). See generally on local government liability, Nahmod, CIVIL RIGHTS AND CIVIL LIBERTIES LITIGATION: THE LAW OF SECTION 1983 (2019)(West, Westlaw).

Now consider the Seventh Circuit’s decision in Glisson v. Indiana Dept. of Corrections, 849 F.3d 372 (7th Cir. 2017)(en banc).

In Glisson, the representative of a prisoner’s estate sued a private medical services provider under contract with the state department of corrections for the prisoner’s death in violation of the Eighth Amendment. The Seventh Circuit said the following in reversing the district court’s grant of summary judgment to the corporate defendant:

It is somewhat unusual to see an Eighth Amendment case relating to medical care in a prison in which the plaintiff does not argue that the individual medical provider was deliberately indifferent to a serious medical need. But unusual does not mean impossible, and this case well illustrates why an organization might be liable even if its individual agents are not. Without the full picture, each person might think that her decisions were an appropriate response to a problem; her failure to situate the care within a broader context could be at worst negligent, or even grossly negligent, but not deliberately indifferent. But if institutional policies are themselves deliberately indifferent to the quality of care provided, institutional liability is possible.

In this case, the Seventh Circuit reasoned, there was sufficient evidence of a conscious policy choice by the defendant not to coordinate medical care either within an institution or across institutions for prisoners who were transferred, and there was also sufficient evidence that it was this policy choice not to require any kind of formal coordination that led to the prisoner’s death. In the course of its opinion, the Seventh Circuit observed that it was breaking no new ground in ruling that the conscious failure to make policy can itself be an actionable policy.

The Seventh Circuit explained:

The central question is always whether an official policy, however expressed (and we have no reason to think that the list in Monell is exclusive), caused the constitutional deprivation. It does not matter if the policy was duly enacted or written down, nor does it matter if the policy counsels aggressive intervention into a particular matter or a hands-off approach. One could easily imagine either kind of strategy for a police department: one department might follow a policy of zero-tolerance for low-level drug activity in a particular area, arresting every small-time seller; while another department might follow a policy of by-passing the lower-level actors in favor of a focus on the kingpins. The hands-off policy is just as much a “policy” as the 100% enforcement policy is.

Judge Sykes dissented, joined by Judges Bauer, Flaum and Kanne. They argued that the majority endorsed Monell liability “without evidence of corporate fault or causation. … The court rests its decision on the conceptual idea that a gap in official policy can sometimes be treated as an actual policy for purposes of municipal liability….” They maintained that in a case like this, a plaintiff must show a pattern of constitutional injuries traceable to the challenged policy or custom. Without such evidence, the defendant was not on notice that protocols were needed.

Comment

The majority has the better of the argument. It has long been clear that a local government (or in this case, a private medical services provider acting under color of law) can be held liable for a failure to act which in turn can constitute an official policy or custom so long as the requisite state of mind (ordinarily deliberate indifference) is proved. It is the entity’s deliberate indifference that determines its section 1983 liability, not necessarily the state of mind of individual employees or officials, although the latter may sometimes be relevant, especially in a policymaker situation. But in this case, the corporate defendant could be held liable for its official policy or custom even if its individual employees or officials might not have committed constitutional violations.

Written by snahmod

September 19, 2019 at 9:04 am

The Knick Case, Takings and Section 1983: A Somewhat Different View

Section 1983 Takings Claims and Williamson County (1985)

In 1985, the Supreme Court held in Williamson County Regional Planning Comm’n v. Hamilton Bank, 473 U.S. 172 (1985),  that a section 1983 takings claim for damages cannot be brought in federal court, and is not ripe, unless the challenged local government conduct is final and the local government has denied compensation. This result was thought to be required by the language of the Fifth Amendment which states that “private property [shall not] be taken for public use, without just compensation.” In effect, Williamson County ruled that the takings claim was not complete until just compensation was denied. This result was also thought to promote the values of federalism and comity.

Accordingly, such a takings plaintiff would first have to go to state court and seek just compensation there–a so-called inverse condemnation action. Only after such a claim failed in state court could the plaintiff proceed in federal court with a “ripe” section 1983 takings claim.

The “Preclusion Trap”

A major problem with Williamson County, which took some years to emerge at the Supreme Court but soon became obvious to takings litigators, was preclusion. Pursuant to 28 U.S.C. sec. 1738, the preclusive effect of a state court decision on a subsequent federal court action is determined by the law of the forum state. And in San Remo Hotel v. City and County of San Francisco, 545 U.S. 323 (2005), the Court indeed held that the resolution of a claim for just compensation by a state court can have preclusive effect on a subsequent federal court action alleging a takings claim. Consequently, where the property owner lost in state court, issue preclusion under state law would typically sound the death knell for the federal court takings claim, or at the very least make it extremely difficult for the federal plaintiff to prevail. Indeed, several justices (Rehnquist, O’Connor, Kennedy and Thomas) questioned Williamson County because of this “preclusion trap.”

The Knick Decision (2019): Williamson County Overruled

On June 21, 2019, the Supreme Court, in Knick v. Township of Scott, No. 17-647,  overruled Williamson County. Dealing with a case in which the district court had dismissed a property owner’s section 1983 takings claim against a local government because she had not pursued an inverse condemnation action in state court, the Court, in an opinion by Chief Justice Roberts, declared:

We now conclude that the state-litigation requirement imposes an unjustifiable burden on takings plaintiffs, conflicts with rest of our takings jurisprudence, and must be overruled. A property owner has an actionable Fifth Amendment takings claims when the government takes his property without paying for it. … [This means] that the property owner has suffered a violation of his Fifth Amendment rights when the government takes his property without just compensation, and may therefore bring his claim in federal court under [section] 1983 at that time.

Justice Kagan, joined by Justices Ginsburg, Breyer and Sotomayor, dissented. They accused the majority of not only misreading the Court’s takings precedents but also of improperly basing its decision simply on its view that Williamson County was wrong.

Comments

First and foremost, Knick is a game-changer and will likely bring about a revolution in takings litigation. This also includes claims of temporary takings, as in First English Evangelical Lutheran Church v. County of Los Angeles, 482 U.S. 304 (1987). No longer will property owners with takings claims against local governments have to exhaust their state judicial remedies as a condition precedent to filing in federal court. They will thus be able to avoid the “preclusion trap” and, moreover, avoid the duplication of litigation and judicial costs.

Second, by eliminating the requirement that section 1983 takings plaintiffs may go directly to federal court, the Court soundly aligned section 1983 takings claims with the ruling in the seminal decision in Monroe v. Pape, 365 U.S. 167 (1965), that, as a matter of statutory interpretation, section 1983 plaintiffs need not exhaust state judicial remedies before filing section 1983 claims in federal court. Knick reached the same conclusion as a matter of constitutional interpretation.

The Court also aligned section 1983 takings claims with what it asserted was the same rule for Fifth Amendment takings claims against the federal government, namely, that “the right to full compensation arises at the time of the taking, regardless of post-taking remedies that may be available to the property owner.”

Perhaps the Court in now-overruled Williamson County was influenced by the then-recent decision in Parratt v. Taylor, 451 U.S. 527 (1981), holding that the existence of an adequate state post-deprivation remedy could defeat certain section 1983 procedural due process claims. Parratt for a time was viewed as a potentially effective vehicle for promoting federalism and comity by removing many procedural due process cases from federal court and sending them to state court where they belonged. It took a while for the Court to narrow the scope of Parratt and to make clear that the Parratt post-deprivation remedy approach was limited to certain procedural due process cases–where the challenged conduct was random and unauthorized–and that it did not apply to other constitutional provisions. See generally ch 3, Nahmod,  CIVIL RIGHT AND CIVIL LIBERTIES LITIGATION: THE LAW OF SECTION 1983 (4th ed. 2018).

Third, as the Court correctly noted, there was no good reason to treat takings claims as constitutional outliers. Other constitutional violations–the Court used the Fourth Amendment as an example–are complete once the challenged conduct is over. The ability to recover damages is not part of the constitutional violation itself : the constitutional merits are separate from the remedy. The rule should always have be the same for takings claims. Knick therefore does not privilege property owners with section 1983 takings claims over other section 1983 plaintiffs. It treats them the same as other section 1983 plaintiffs with different constitutional claims for damages.

Fourth, in my view the underlying issue in dispute among the justices in Knick was stare decisis. The four dissenting justices were concerned with what they view as the current majority’s predisposition to overrule precedents such as Williamson County just because it doesn’t like those precedents. Knick and other recent decisions that have overruled precedents, and that have been fought over by the justices, may really be a rehearsal for challenges to, and the possible overruling of, Roe v. Wade.

Fifth, coming so soon after the Court’s accrual decision in McDonough v. Smith (No. 18-485),  Knick itself may be viewed as a kind of accrual decision. From this perspective, Knick holds that the section 1983 takings claim is complete, and thus accrues, when the taking occurs, and not later when the state or local government denies just compensation.

(See my post on McDonough here: https://nahmodlaw.com/2019/06/21/mcdonough-v-smith-the-supreme-court-answers-an-important-section-1983-fabrication-of-evidence-accrual-question/)

Finally, while I think the Court got Knick right, the Court’s approach–simplifying section 1983 takings claims–is inconsistent with its May 28, 2019, section 1983 First Amendment retaliatory arrest decision in Nieves v. Bartlett, No. 17-1174. In Nieves, the Court unsoundly imposed unduly burdensome procedural and substantive requirements on section 1983 plaintiffs who sue law enforcement officers for damages for allegedly arresting them in violation of the First Amendment. Among other things, the Court ruled that probable cause is a defense to such claims. Why such solicitude for section 1983 takings plaintiffs in Knick and so little concern for section 1983 First Amendment plaintiffs in Nieves? Probable cause should be as irrelevant to the First Amendment as it is to takings.

(See my post criticizing Nieves here:  https://nahmodlaw.com/2019/06/04/nieves-v-bartlett-and-retaliatory-arrests-protecting-law-enforcement-at-the-expense-of-the-first-amendment-and-section-1983/)

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Written by snahmod

July 25, 2019 at 9:04 am