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Keywords

plaintiffattorneyinjunctionappealcompliance
plaintiffdefendantattorneyfelony

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Miller v. Mitchell, 598 F.3d 139, 73 A.L.R.6th 719

Facts

In 2008, the District Attorney of Wyoming County, Pennsylvania, threatened to prosecute minors suspected of 'sexting' unless they attended an education program he had developed. The plaintiffs, parents of the minors, alleged that this threat was retaliatory and violated their constitutional rights. The District Court granted a preliminary injunction against the District Attorney, who appealed the decision. During the appeal, the District Attorney decided not to file charges against two of the minors, but the case continued for one remaining minor and her mother.

In 2008, the District Attorney of Wyoming County in Pennsylvania presented teens suspected of “sexting” with a choice: either attend an education program designed by the District Attorney in conjunction with two other agencies or face felony child pornography charges.

Issue

Did the District Attorney's threat of prosecution against the minors for not attending an educational program constitute retaliation in violation of their First and Fourteenth Amendment rights?

Did the District Attorney's threat of prosecution against the minors for not attending an educational program constitute retaliation in violation of their First and Fourteenth Amendment rights?

Rule

To establish a retaliation claim under § 1983, a plaintiff must show that they engaged in constitutionally protected activity, that the government responded with retaliation, and that the protected activity caused the retaliation.

To state a claim under § 1983, plaintiffs must show that the defendant, under the color of state law, deprived them of a federal constitutional or statutory right.

Analysis

The court determined that the District Attorney's threats to prosecute the minors for not attending the education program were retaliatory actions in response to their refusal to participate. The court found that the minors had a constitutional right to refuse to attend the program, and the attorney's threats were aimed at coercing them into compliance. The court also noted that the education program's requirements interfered with the parents' rights to direct their children's upbringing.

The court determined that the District Attorney's threats to prosecute the minors for not attending the education program were retaliatory actions in response to their refusal to participate.

Conclusion

The Court of Appeals affirmed the District Court's decision to grant a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their retaliation claims.

Accordingly, we affirm.

Who won?

The plaintiffs prevailed in the case because the court found that the District Attorney's threats constituted unconstitutional retaliation against the minors for exercising their rights.

We agree with the District Court that they have shown a likelihood of success on the merits of their constitutional retaliation claims, and therefore they are entitled to preliminary injunctive relief.

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