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Supreme Court decisions
No. 22-1025Jun 20, 2024Civil Rights and Liberties, Minority IssuesVacated and remanded

The question

Whether a First Amendment retaliatory-arrest plaintiff must produce specific evidence of otherwise-similar people who were not arrested to fit the exception recognized in Nieves v. Bartlett.

Gonzalez v. Trevino

What the Court decided

The Court held that the Fifth Circuit read the Nieves exception too narrowly. A plaintiff claiming she was arrested in retaliation for protected speech need not produce a specific comparator, a near-identical person who was not arrested; other objective evidence can suffice. The case was sent back to apply that broader standard.

How the justices split

Unanimous
In favor 9
Roberts
Thomas
Alito
Sotomayor
Kagan
Gorsuch
Kavanaugh
Barrett
Jackson

Per curiam (unsigned)

Delivered by the Court

The Nieves exception, which lets a retaliatory-arrest plaintiff proceed despite probable cause, requires only objective evidence that she was treated differently from others who were not engaged in protected speech. It does not demand a specific comparator. The Fifth Circuit erred by requiring one.

How we know · 2 sourced claims
  • The Court held the Fifth Circuit took an overly narrow view of the Nieves retaliatory-arrest exception.

    Source: syllabus, Held, at 22-1025

  • A plaintiff need not produce a specific comparator; other objective evidence can suffice.

    Source: opinion (per curiam)

Read the opinion on supremecourt.gov