Fraternal Order of Police, Lodge 1 v. City of Camden, 842 F.3d 231

Camden instituted a 2008 "directed patrols" program requiring 15–20 minute police-civilian encounters logged in the CAD system; officers were to ask about criminal activity and could collect names/addresses.
FOP Lodge 1 and several officers sued, alleging the policy functioned as an illegal quota under N.J. Stat. § 40A:14-181.2 and that officers who objected suffered retaliation (CEPA, First Amendment, FMLA).
Individual plaintiffs claimed adverse actions including placement on a "low-performer" list, transfers from an elite unit (with pay/status loss), disciplinary charges, vacation revocations, sick-leave restrictions, and Internal Affairs scrutiny.
The district court granted summary judgment to defendants on all claims, holding (inter alia) the NJ anti-quota statute only covers arrests/citations (not encounters), no causal link for CEPA/First Amendment claims, and no actionable FMLA interference.
On appeal the Third Circuit affirmed dismissal of the anti-quota, First Amendment, and FMLA claims, but reversed as to CEPA retaliatory-transfer claims and held the district court improperly excluded hearsay evidence at summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of NJ anti-quota statute	Directed patrols are de facto quota because officers must meet numeric patrol/encounter targets	Statute only prohibits quotas for arrests or citations; encounters are outside its scope	Affirmed for defendants — statute covers only arrests/citations, not encounters
CEPA retaliation (prima facie elements; causation)	Officers reasonably believed the patrols violated law and the objections led to adverse actions (transfers/demotions)	Actions were due to deficient performance; no causal link to protected whistleblowing	Reversed in part — officers satisfied CEPA's first and third prongs re: transfers; causation is a jury question; summary judgment improper; some minor actions not adverse under CEPA
First Amendment retaliation	Objections to policy address matter of public concern and were protected speech	Officers spoke pursuant to official duties (internal counseling forms), so not protected; no causation	Affirmed for defendants — speech was made pursuant to official duties (Garcetti) and not protected
FMLA interference (Holland)	Placement on chronic sick list and threats chilled use of approved FMLA leave and deterred exercise of rights	Any questioning was due to miscommunication; actions not severe enough to deter a person of ordinary firmness; no prejudice shown	Affirmed for defendants — conduct insufficiently chilling and no showing of prejudice or denial of FMLA rights

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standards and admissible-form requirement)
Garcetti v. Ceballos, 547 U.S. 410 (public-employee speech made pursuant to official duties not protected by the First Amendment)
Pickering v. Board of Education, 391 U.S. 563 (public-employee speech on matters of public concern balancing test)
Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (FMLA requires prejudice/injury for relief)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-step analysis)
Reichle v. Howards, 132 S. Ct. 2088 (qualified immunity and retaliatory arrest context)
Caver v. City of Trenton, 420 F.3d 243 (CEPA/retaliation framework)
Blackburn v. United Parcel Serv., Inc., 179 F.3d 81 (CEPA interpretation and remedial construction)
Stelwagon Mfg. Co. v. Tarmac Roofing Sys., 63 F.3d 1267 (admissibility of hearsay on summary judgment)
Gorum v. Sessoms, 561 F.3d 179 (applying Garcetti and citizen/employee speech analysis)