Nathan Rinne v. Camden County, 65 F.4th 378

In March 2021 the three-member Camden County Commission voted (2–1) to ban Nathan Rinne from county property for one year for alleged "disruptive conduct and harassment." Commissioner Greg Hasty cast the deciding vote.
Rinne had publicly criticized the Commission and Hasty at meetings and on Facebook; he alleges the ban was retaliatory and pretextual.
Rinne sued Hasty and the County under 42 U.S.C. § 1983, seeking damages from Hasty and a preliminary injunction barring enforcement of the ban.
The district court denied Hasty’s qualified immunity motion and granted the preliminary injunction; the Commission later sent a letter repealing the ban and stating it would not reinstate it.
On appeal, the Eighth Circuit affirmed denial of qualified immunity (damages claim against Hasty survives) but held the appeal of the injunction moot because the one‑year ban expired by its terms on March 2, 2022, and Rinne lacked a demonstrated, imminent threat of a similar future ban.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment retaliation	Rinne: public criticisms are protected; the ban chills speech	Hasty: Rinne continued speaking; ban did not objectively chill	Court: Speech protected; the one‑year exclusion and threat of enforcement would chill an ordinary person; plausible retaliatory motive alleged, so claim survives
Qualified immunity for a voting official	Rinne: Hasty’s vote that imposed the ban is actionable	Hasty: law not clearly established that a single voting member can be liable	Court: Precedent shows board members can be liable for collective actions (Strickland); Hasty cast the deciding vote (but‑for cause); no qualified immunity at pleading stage
Mootness of preliminary injunction & scope of future relief	Rinne: injunction necessary; repeal might be voluntary cessation	Defs: ban expired March 2, 2022; repeal moots controversy; future‑ban injunction speculative	Court: appeal of injunction is moot because ban expired by its terms; no standing for broad injunction against hypothetical future, similar bans; vacate/dismiss injunctive relief as moot

Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint plausibility standard)
Strickland v. Inlow, 485 F.2d 186 (8th Cir. 1973) (individual board members subject to § 1983 liability for board decisions)
Hartman v. Moore, 547 U.S. 250 (2006) (retaliation for protected speech is unconstitutional)
Bennie v. Munn, 822 F.3d 392 (8th Cir. 2016) (objective, ordinary‑firmness chilling test)
Garcia v. City of Trenton, 348 F.3d 726 (8th Cir. 2003) (governmental punitive actions can chill speech)
Already, LLC v. Nike, Inc., 568 U.S. 85 (2013) (mootness when challenged action expired by its terms)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167 (2000) (standing and mootness analysis)