Desjardins v. Willard
2015 U.S. App. LEXIS 1051
| 1st Cir. | 2015Background
- Desjardins, a Raymond, Maine town official, sued fellow official Michael Reynolds (and initially Town Manager Donald Willard) alleging Reynolds falsely told the county sheriff that Desjardins attended meetings drunk and drove while intoxicated, causing reputation harm and being "red-flagged" and stopped by deputies.
- Suit was filed in Cumberland County Superior Court asserting state-law defamation and false light claims and federal § 1983 claims (Fourth Amendment unreasonable seizure; Fourteenth Amendment stigma-plus liberty interest). Case was removed to federal court based on the federal claims.
- The district court dismissed the federal claims and dismissed claims against Willard; it also dismissed the remaining state claims against Reynolds under Maine's Anti‑SLAPP law, relying on Maine precedent.
- On appeal the First Circuit affirmed dismissal of the federal claims: (1) no proximate cause linking Reynolds to the traffic stop (Fourth Amendment); (2) no cognizable stigma‑plus claim because reputational stigma and the alleged tangible harms derived from distinct sources (Fourteenth Amendment).
- The First Circuit concluded the remaining state-law defamation and false light claims presented unsettled questions of state law (including potential tension between Maine Anti‑SLAPP precedent and later Maine decisions) and remanded those claims to Maine state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fourth Amendment (unreasonable seizure) | Reynolds’ false report led deputies to stop Desjardins, causing an unconstitutional seizure. | No proximate causation; Reynolds’ request to send a deputy to a meeting did not cause the traffic stop. | Dismissed: complaint fails to plausibly allege proximate causation. |
| Fourteenth Amendment (stigma‑plus due process) | Defamatory acts caused reputational stigma plus tangible harms (red‑flagging, traffic stop) giving rise to a liberty interest violation. | Reputational harm and tangible harms derive from distinct sources; stigma‑plus not pled. | Dismissed: plaintiff did not allege the required stigma‑plus directly attributable to the same governmental action. |
| Supplemental jurisdiction over state claims | Federal court should retain and resolve state claims after dismissing federal anchors for judicial economy and fairness. | Court can decline supplemental jurisdiction; state claims raise important state‑law issues better resolved by state courts. | Remand: after dismissal of federal claims and departure of Willard, balance favors remanding state claims to state court. |
| Application of Maine Anti‑SLAPP law vs. state constitutional remedies | Anti‑SLAPP dismissal forecloses Desjardins’ state claims because damages per se insufficient under Schelling. | Nader and constitutional concerns may limit Anti‑SLAPP application; these state‑law tensions should be decided by Maine courts. | Remand: leave unresolved at federal level; state court should decide the Anti‑SLAPP/constitutional interplay. |
Key Cases Cited
- Ocasio‑Hernández v. Fortuño‑Burset, 640 F.3d 1 (1st Cir. 2011) (proximate causation analysis for § 1983 claims)
- Mead v. Independence Ass'n, 684 F.3d 226 (1st Cir. 2012) (explaining stigma‑plus requirement for due process reputational claims)
- URI Student Senate v. Town of Narragansett, 631 F.3d 1 (1st Cir. 2011) (stigma‑plus framework and need for tangible injury directly attributable to challenged action)
- Camelio v. Am. Fed'n, 137 F.3d 666 (1st Cir. 1998) (factors for declining supplemental jurisdiction and remanding state claims)
- Rivera‑Díaz v. Humana Ins. of P.R., Inc., 748 F.3d 387 (1st Cir. 2014) (federal guidance favoring dismissal of federal claims and remand of remaining state claims)
- Carnegie‑Mellon Univ. v. Cohill, 484 U.S. 343 (1988) (Supreme Court guidance on discretionary remand of pendent state claims)
- Schelling v. Lindell, 942 A.2d 1226 (Me. 2008) (Maine SJC: damages per se do not satisfy Anti‑SLAPP actual injury requirement)
- Nader v. Maine Democratic Party, 41 A.3d 551 (Me. 2012) (Maine SJC refining Anti‑SLAPP application to avoid constitutional problems)