⚖ Oral Arguments, with Context

The U.S. Court of Appeals for the Eleventh Circuit hears Laquana Alexander versus Patrick Labat. The core legal issue is whether a county sheriff acted under color of state law when he filed a temporary protective order against a citizen who had publicly criticized him on his official government web page. Ms. Alexander posted comments accusing Sheriff Labat of misappropriating funds and other misconduct related to his performance as sheriff; members of the panel noted that some of the posts were also personal, about him and his wife, though the parties agree the speech was protected. He then sought a temporary protective order through a private attorney; the TPO proceeding ended without a final order. Alexander alleges the filing was a response to her posts. Alexander sued under Section 1983, claiming First Amendment retaliation. The district court dismissed the complaint and denied leave to amend. On appeal, Alexander argues that the sheriff's response to her protected speech constitutes state action, and that calling it private conduct would let any official retaliate against critics through legal processes nominally open to everyone. The sheriff contends he acted as any private citizen could when seeking a protective order. The case turns on a question that threads through many civil rights disputes: when does a public official's conduct qualify as official action subject to constitutional limits, and when is it simply private conduct available to anyone?

Laquana Alexander v. Patrick Labat (No. 25-11573) — U.S. Court of Appeals for the Eleventh Circuit, argued July 31, 2026.