O'Connor-Ratcliff v. Garnier

Michelle O'Connor-Ratcliff and T.J. Zane, trustees of the Poway Unified School District Board in California, used their personal Facebook and Twitter accounts to post about official district business. Christopher and Kimberly Garnier, parents of students in the district, frequently posted repetitive and critical comments on the trustees' posts. In response, the trustees blocked the Garniers from their social media pages. The Garniers sued, arguing the blocking violated their First Amendment free speech rights. The district court found in favor of the Garniers, a decision affirmed by the Ninth Circuit. The Supreme Court vacated the judgment and remanded the case, directing the lower courts to apply the new standard established in the companion case Lindke v. Freed to determine if the trustees' blocking constituted state action.

The U.S. Supreme Court vacated the Ninth Circuit’s judgment and remanded the case. The ruling instructed lower courts to apply the test from the companion case, Lindke v. Freed, which held that a public official’s social media activity constitutes state action only if the official possessed actual authority to speak on the government’s behalf and purported to exercise that authority.

The central dispute was whether a public official who blocks a constituent from their personal social media accounts, which are used to communicate about official duties, engages in "state action" that violates the First Amendment.

The decision provided crucial guidance on the legal boundaries for public officials using social media. It clarified the distinction between personal and official capacity online, impacting how elected officials, government agencies, and employees manage their social media interactions. The ruling protects the public's right to petition and comment on government matters in the digital public square while acknowledging the personal speech rights of officials.