778 F.Supp.3d 1201
D. Wyo.2025Background
- Terri Lesley, a former Executive Director of the Campbell County Public Library System (CCPLS) in Wyoming, alleges that the Bennetts and other county officials conspired to deprive her and the LGBTQ+ community of constitutional rights related to library content and programming.
- The dispute arose after Lesley and library staff highlighted LGBTQ+ inclusive books and events during Pride Month on library social media, which triggered sustained criticism and pressure from the Bennetts and allied commissioners to censor such content.
- Lesley claims a coordinated effort to intimidate her and force removal of LGBTQ+ and certain racially diverse books, through public meetings, threats, and demands for her resignation, eventually resulting in her termination.
- The lawsuit alleges violations under 42 U.S.C. § 1985(1) & (3), civil conspiracy, intentional infliction of emotional distress (IIED), injurious falsehood, and abuse of process.
- The court addressed the defendants' motion to dismiss, examining whether Lesley's pleadings stated plausible claims for each cause of action under federal and state law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| §1985(1) (Ku Klux Klan Act): Interference with federal duties | Lesley says she was blocked from public duties in violation of §1985(1) | Only federal officers are covered by §1985(1); Lesley is not federal | Dismissed (Lesley not a federal officeholder) |
| §1985(3): Deprivation of equal protection (class-based animus) | Defendants targeted Lesley due to her advocacy for LGBTQ+ and racial minorities; state action involved | LGBTQ+ status is not a protected class; Lesley is not LGBTQ+; actions not covered | Denied dismissal; claim to proceed due to sexual orientation and advocacy for protected groups (LGBTQ+ & racial minorities) |
| Civil conspiracy (Wyoming law) | Defendants conspired to violate rights and commit torts like IIED | Lesley didn't plead a valid underlying tort | Denied dismissal; plausible claim present (including IIED) |
| Intentional infliction of emotional distress | Defendants' conduct was outrageous, caused distress | Actions not sufficiently outrageous; no malice, Lesley a public figure | Denied dismissal; plausible claim, but impact evidence thin at this stage |
| Injurious falsehood (business disparagement) | Defendants' statements constituted injurious falsehood | No Wyoming precedent for this tort for non-business interests | Dismissed under Wyoming law |
| Abuse of process | Filing criminal complaint was ulterior use of process | Filing of complaint was proper, not misuse | Dismissed; merely filing a report is not abuse |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards for federal complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
- Kush v. Rutledge, 460 U.S. 719 (1983) (scope of §1985(1) applies only to interference with federal officers)
- Griffin v. Breckenridge, 403 U.S. 88 (1971) (parameters of §1985(3) covering racial/class-based conspiracies)
- United Bhd. of Carpenters & Joiners of Am., Local 610, AFL-CIO v. Scott, 463 U.S. 825 (1983) (limits of §1985(3), deprivation clause)
- Bray v. Alexandria Women's Health Clinic, 506 U.S. 263 (1993) (clarification on class-based animus under §1985(3))
- Lugar v. Edmondson Oil Co., 457 U.S. 922 (1982) (state action doctrine)
- Hoblyn v. Johnson, 55 P.3d 1219 (Wyo. 2002) (defining IIED standard in Wyoming)
- White v. Shane Edeburn Const., LLC, 285 P.3d 949 (Wyo. 2012) (elements of civil conspiracy in Wyoming)
- Toltee Watershed Imp. Dist. v. Johnston, 717 P.2d 808 (Wyo. 1986) (elements of abuse of process in Wyoming)