Lindke v. Freed

Summary

The Court held that a public official's social‑media activity constitutes state action for §1983 liability only if the official (1) possessed actual authority to speak on the State’s behalf and (2) purported to exercise that authority; applying this test, James Freed’s deletion and blocking of comments did not satisfy either prong, so Lindke’s claim fails. The judgment of the Sixth Circuit was vacated and the case remanded for further proceedings consistent with this test.