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															SUPREME COURT OF THE UNITED STATES

															_________________

															No. 22–611

															_________________

															KEVIN LINDKE, PETITIONER v. JAMES R.
FREED

															on writ of certiorari to the united states
court of appeals for the sixth circuit

															[March 15, 2024]

															Justice Barrett delivered the opinion of the
Court.

															Like millions of Americans, James Freed
maintained a Facebook account on which he posted about a wide range
of topics, including his family and his job. Like most of those
Americans, Freed occasionally received unwelcome comments on his
posts. In response, Freed took a step familiar to Facebook users:
He deleted the comments and blocked those who made them.

															For most people with a Facebook account, that
would have been the end of it. But Kevin Lindke, one of the
unwelcome commenters, sued Freed for violating his right to free
speech. Because the First Amendment binds only the government, this
claim is a nonstarter if Freed posted as a private citizen. Freed,
however, is not only a private citizen but also the city manager of
Port Huron, Michigan—and while Freed insists that his Facebook
account was strictly personal, Lindke argues that Freed acted in
his official capacity when he silenced Lindke’s speech.

															When a government official posts about
job-related topics on social media, it can be difficult to tell
whether the speech is official or private. We hold that such speech
is attributable to the State only if the official
(1) possessed actual authority to speak on the State’s behalf,
and (2) purported to exercise that authority when he spoke on
social media.

															I

															A

															Sometime before 2008, while he was a college
student, James Freed created a private Facebook profile that he
shared only with “friends.” In Facebook lingo, “friends” are not
necessarily confidants or even real-life acquaintances. Users
become “friends” when one accepts a “friend request” from another;
after that, the two can generally see and comment on one another’s
posts and photos. When Freed, an avid Facebook user, began nearing
the platform’s 5,000-friend limit, he converted his profile to a
public “page.” This meant that anyone could see and comment
on his posts. Freed chose “public figure” for his page’s category,
“James Freed” for its title, and “JamesRFreed1” as his username.
Facebook did not require Freed to satisfy any special criteria
either to convert his Facebook profile to a public page or to
describe himself as a public figure.

															In 2014, Freed was appointed city manager of
Port Huron, Michigan, and he updated his Facebook page to reflect
the new job. For his profile picture, Freed chose a photo of
himself in a suit with a city lapel pin. In the “About” section,
Freed added his title, a link to the city’s website, and the city’s
general email address. He described himself as “Daddy to Lucy,
Husband to Jessie and City Manager, Chief Administrative Officer
for the citizens of Port Huron, MI.”

															As before his appointment, Freed operated his
Facebook page himself. And, as before his appointment, Freed posted
prolifically (and primarily) about his personal life. He uploaded
hundreds of photos of his daughter. He shared about outings like
the Daddy Daughter Dance, dinner with his wife, and a family nature
walk. He posted Bible verses, updates on home-improvement projects,
and pictures of his dog, Winston.

															Freed also posted information related to his
job. He described mundane activities, like visiting local high
schools, as well as splashier ones, like starting reconstruction of
the city’s boat launch. He shared news about the city’s efforts to
streamline leaf pickup and stabilize water intake from a local
river. He highlighted communications from other city officials,
like a press release from the fire chief and an annual financial
report from the finance department. On occasion, Freed solicited
feedback from the public—for instance, he once posted a link to a
city survey about housing and encouraged his audience to complete
it.

															Freed’s readers frequently commented on his
posts, sometimes with reactions (for example, “Good job it takes
skills” on a picture of his sleeping daughter) and sometimes with
questions (for example, “Can you allow city residents to have
chickens?”). Freed often replied to the comments, including by
answering inquiries from city residents. (City residents can have
chickens and should “call the Planning Dept for details.”) He
occasionally deleted comments that he thought were “derogatory” or
“stupid.”

															After the COVID–19 pandemic began, Freed posted
about that. Some posts were personal, like pictures of his family
spending time at home and outdoors to “[s]tay safe” and “[s]ave
lives.” Some contained general information, like case counts and
weekly hospitalization numbers. Others related to Freed’s job, like
a description of the city’s hiring freeze and a screenshot of a
press release about a relief package that he helped prepare.

															Enter Kevin Lindke. Unhappy with the city’s
approach to the pandemic, Lindke visited Freed’s page and said so.
For example, in response to one of Freed’s posts, Lindke commented
that the city’s pandemic response was “abysmal” and that “the city
deserves better.” When Freed posted a photo of himself and the
mayor picking up takeout from a local restaurant, Lindke complained
that while “residents [we]re suffering,” the city’s leaders were
eating at an expensive restaurant “instead of out talking to the
community.” Initially, Freed deleted Lindke’s comments; ultimately,
he blocked him. Once blocked, Lindke could see Freed’s posts but
could no longer comment on them.

															B

															Lindke sued Freed under 42 U. S. C.
§1983, alleging that Freed had violated his First Amendment rights.
As Lindke saw it, he had the right to comment on Freed’s Facebook
page, which he characterized as a public forum. Freed, Lindke
claimed, had engaged in impermissible viewpoint discrimination by
deleting unfavorable comments and blocking the people who made
them.

															The District Court granted summary judgment to
Freed. Because only state action can give rise to liability under
§1983, Lindke’s claim depended on whether Freed acted in a
“private” or “public” capacity. 563 F. Supp. 3d 704, 714 (ED
Mich. 2021). The “prevailing personal quality of Freed’s post[s],”
the absence of “government involvement” with his account, and the
lack of posts conducting official business led the court to
conclude that Freed managed his Facebook page in his private
capacity, so Lindke’s claim failed. Ibid .

															The Sixth Circuit affirmed. It noted that “the
caselaw is murky as to when a state official acts personally and
when he acts officially” for purposes of §1983. 37 F. 4th
1199, 1202 (2022). To sort the personal from the official, that
court “asks whether the official is ‘performing an actual or
apparent duty of his office,’ or if he could not have behaved as he
did ‘without the authority of his office.’ ” Id ., at
1203 (quoting Waters v. Morristown , 242 F.3d 353 , 359 (CA6 2001)). Applying this precedent to the
social-media context, the Sixth Circuit held that an official’s
activity is state action if the “text of state law requires an
officeholder to maintain a social-media account,” the official
“use[s] . . . state resources” or “government
staff ” to run the account, or the “accoun[t] belong[s] to an
office, rather than an individual officeholder.” 37 F. 4th, at
1203–1204. These situations, the Sixth Circuit explained, make an
official’s social-media activity “ ‘fairly
attributable’ ” to the State. Id ., at 1204 (quoting Lugar v. Edmondson Oil Co. , 457
U.S. 922 , 937 (1982)). And it concluded that Freed’s activity
was not.

															The Sixth Circuit’s approach to state action in
the social-media context differs from that of the Second and Ninth
Circuits, which focus less on the connection between the official’s
authority and the account and more on whether the account’s
appearance and content look official. See, e . g ., Garnier v. O’Connor-Ratcliff , 41 F. 4th 1158,
1170–1171 (CA9 2022); Knight First Amdt. Inst. at Columbia
Univ. v. Trump , 928 F.3d 226, 236 (CA2 2019), vacated as
moot sub nom . Biden v. Knight First Amdt.
Inst. at Columbia Univ ., 593 U. S. ___ (2021). We granted
certiorari. 598 U. S. ___ (2023).

															II

															Section 1983 provides a cause of action
against “[e]very person who, under color of any statute,
ordinance, regulation, custom, or usage, of any State ” deprives
someone of a federal constitutional or statutory right. (Emphasis
added.) As its text makes clear, this provision protects against
acts attributable to a State, not those of a private person. This
limit tracks that of the Fourteenth Amendment, which obligates States to honor the constitutional rights that §1983
protects. §1 (“No State shall . . . nor shall any State deprive . . . ” (emphasis added)); see also Lugar , 457 U. S., at 929 (“[T]he statutory requirement
of action ‘under color of state law’ and the ‘state action’
requirement of the Fourteenth Amendment are identical”). The need
for governmental action is also explicit in the Free Speech Clause,
the guarantee that Lindke invokes in this case. Amdt. 1
(“ Congress shall make no law . . . abridging the
freedom of speech . . . ” (emphasis added)); see also Manhattan Community Access Corp. v. Halleck , 587 U.S.
802, 808 (2019) (“[T]he Free Speech Clause prohibits only governmental abridgment of speech,” not “ private abridgment of speech”). In short, the state-action requirement is
both well established and reinforced by multiple sources.[ 1 ]

															In the run-of-the-mill case, state action is
easy to spot. Courts do not ordinarily pause to consider whether
§1983 applies to the actions of police officers, public schools, or
prison officials. See, e . g ., Graham v. Connor , 490 U.S.
386 , 388 (1989) (police officers); Tinker v. Des
Moines Independent Community School Dist. , 393 U.S.
503 , 504–505 (1969) (public schools); Estelle v. Gamble , 429 U.S.
97 , 98 (1976) (prison officials). And, absent some very unusual
facts, no one would credit a child’s assertion of free speech
rights against a parent, or a plaintiff ’s complaint that a
nosy neighbor unlawfully searched his garage.

															Sometimes, however, the line between private
conduct and state action is difficult to draw. Griffin v. Maryland is a good example. 378 U.S.
130 (1964). There, we held that a security guard at a privately
owned amusement park engaged in state action when he enforced the
park’s policy of segregation against black protesters. Id .,
at 132–135. Though employed by the park, the guard had been
“deputized as a sheriff of Montgomery County” and possessed
“ ‘the same power and authority’ ” as any other deputy
sheriff. Id ., at 132, and n. 1. The State had therefore
allowed its power to be exercised by someone in the private sector.
And the source of the power, not the identity of the employer,
controlled.

															By and large, our state-action precedents have
grappled with variations of the question posed in Griffin :
whether a nominally private person has engaged in state action for
purposes of §1983. See, e.g. , Marsh v. Alabama , 326 U.S.
501 , 502–503 (1946) (company town); Adickes v. S. H.
Kress & Co. , 398 U.S.
144 , 146–147 (1970) (restaurant); Flagg Bros., Inc. v. Brooks , 436 U.S.
149 , 151–152 (1978) (warehouse company). Today’s case, by
contrast, requires us to analyze whether a state official engaged in state action or functioned as a private citizen. This
Court has had little occasion to consider how the state-action
requirement applies in this circumstance.

															The question is difficult, especially in a case
involving a state or local official who routinely interacts with
the public. Such officials may look like they are always on the
clock, making it tempting to characterize every encounter as part
of the job. But the state-action doctrine avoids such broad-brush
assumptions—for good reason. While public officials can act on
behalf of the State, they are also private citizens with their own
constitutional rights. By excluding from liability “acts of
officers in the ambit of their personal pursuits,” Screws v. United States , 325 U.S.
91 , 111 (1945) (plurality opinion), the state-action
requirement “protects a robust sphere of individual liberty” for
those who serve as public officials or employees, Halleck ,
587 U. S., at 808.

															The dispute between Lindke and Freed illustrates
this dynamic. Freed did not relinquish his First Amendment rights
when he became city manager. On the contrary, “the First Amendment
protects a public employee’s right, in certain circumstances, to
speak as a citizen addressing matters of public concern.” Garcetti v. Ceballos , 547 U.S.
410 , 417 (2006). This right includes the ability to speak about
“information related to or learned through public employment,” so
long as the speech is not “itself ordinarily within the scope of
[the] employee’s duties.” Lane v. Franks , 573 U.S.
228 , 236, 240 (2014). Where the right exists, “editorial
control over speech and speakers on [the public employee’s]
properties or platforms” is part and parcel of it. Halleck ,
587 U. S., at 816. Thus, if Freed acted in his private
capacity when he blocked Lindke and deleted his comments, he did
not violate Lindke’s First Amendment rights—instead, he exercised
his own.

															So Lindke cannot hang his hat on Freed’s status
as a state employee. The distinction between private conduct and
state action turns on substance, not labels: Private parties can
act with the authority of the State, and state officials have
private lives and their own constitutional rights. Categorizing
conduct, therefore, can require a close look.

															III

															A close look is definitely necessary in the
context of a public official using social media. There are
approximately 20 million state and local government employees
across the Nation, with an extraordinarily wide range of job
descriptions—from Governors, mayors, and police chiefs to teachers,
healthcare professionals, and transportation workers. Many use
social media for personal communication, official communication, or
both—and the line between the two is often blurred. Moreover,
social media involves a variety of different and rapidly changing
platforms, each with distinct features for speaking, viewing, and
removing speech. The Court has frequently emphasized that the
state-action doctrine demands a fact-intensive inquiry. See, e.g. , Reitman v. Mulkey , 387 U.S.
369 , 378 (1967); Gilmore v. Montgomery , 417 U.S.
556 , 574 (1974). We repeat that caution here.

															That said, our precedent articulates principles
that govern cases analogous to this one. For the reasons we explain
below, a public official’s social-media activity constitutes state
action under §1983 only if the official (1) possessed actual
authority to speak on the State’s behalf, and (2) purported to
exercise that authority when he spoke on social media. The
appearance and function of the social-media activity are relevant
at the second step, but they cannot make up for a lack of state
authority at the first.

															A

															The first prong of this test is grounded in
the bedrock requirement that “the conduct allegedly causing the
deprivation of a federal right be fairly attributable to the
State .” Lugar , 457 U. S., at 937 (emphasis added).
An act is not attributable to a State unless it is traceable to the
State’s power or authority. Private action—no matter how “official”
it looks—lacks the necessary lineage.

															This rule runs through our cases. Griffin stresses that the security guard was “possessed of state authority”
and “purport[ed] to act under that authority.” 378 U. S., at
135. West v. Atkins states that the “traditional
definition” of state action “requires that the defendant
. . . have exercised power ‘possessed by virtue of state
law and made possible only because the wrongdoer is clothed with
the authority of state law.’ ” 487 U.S.
42 , 49 (1988) (quoting United States v. Classic , 313 U.S.
299 , 326 (1941)). Lugar emphasizes that state action
exists only when “the claimed deprivation has resulted from the
exercise of a right or privilege having its source in state
authority.” 457 U. S., at 939; see also, e . g ., Edmonson v. Leesville Concrete Co. , 500 U.S.
614 , 620 (1991) (describing state action as the “exercise of a
right or privilege having its source in state authority”); Screws , 325 U. S., at 111 (plurality opinion)
(police-officer defendants “were authorized to make an arrest and
to take such steps as were necessary to make the arrest
effective”). By contrast, when the challenged conduct “entail[s]
functions and obligations in no way dependent on state authority,”
state action does not exist. Polk County v. Dodson , 454 U.S.
312 , 318–319 (1981) (no state action because criminal defense
“is essentially a private function . . . for which state
office and authority are not needed”); see also Jackson v. Metropolitan Edison Co. , 419 U.S.
345 , 358–359 (1974).

															Lindke’s focus on appearance skips over this
crucial step. He insists that Freed’s social-media activity
constitutes state action because Freed’s Facebook page looks and
functions like an outlet for city updates and citizen concerns. But
Freed’s conduct is not attributable to the State unless he was
“possessed of state authority” to post city updates and register
citizen concerns. Griffin , 378 U. S., at 135. If the
State did not entrust Freed with these responsibilities, it cannot
“fairly be blamed” for the way he discharged them. Lugar ,
457 U. S., at 936. Lindke imagines that Freed can conjure the
power of the State through his own efforts. Yet the presence of
state authority must be real, not a mirage.

															Importantly, Lindke must show more than that
Freed had some authority to communicate with residents on
behalf of Port Huron. The alleged censorship must be connected to
speech on a matter within Freed’s bailiwick. For example, imagine
that Freed posted a list of local restaurants with health-code
violations and deleted snarky comments made by other users. If
public health is not within the portfolio of the city manager, then
neither the post nor the deletions would be traceable to Freed’s
state authority—because he had none. For state action to exist, the
State must be “responsible for the specific conduct of which the
plaintiff complains.” Blum v. Yaretsky , 457 U.S.
991 , 1004 (1982) (emphasis deleted). There must be a tie
between the official’s authority and “the gravamen of the
plaintiff ’s complaint.” Id ., at 1003.

															To be clear, the “[ m ] isuse of
power, possessed by virtue of state law,” constitutes state action. Classic , 313 U. S., at 326 (emphasis added); see also, e . g ., Screws , 325 U. S., at 110
(plurality opinion) (state action where “the power which [state
officers] were authorized to exercise was misused”). While the
state-action doctrine requires that the State have granted an
official the type of authority that he used to violate
rights— e . g ., the power to arrest—it encompasses cases
where his “particular action”— e.g. , an arrest made with
excessive force—violated state or federal law. Griffin , 378
U. S., at 135; see also Home Telephone & Telegraph
Co. v. Los Angeles , 227 U.S.
278 , 287–288 (1913) (the Fourteenth Amendment encompasses
“abuse by a state officer . . . of the powers
possessed”). Every §1983 suit alleges a misuse of power, because no
state actor has the authority to deprive someone of a federal
right. To misuse power, however, one must possess it in the first
place.

															Where does the power come from? Section 1983
lists the potential sources: “statute, ordinance, regulation,
custom, or usage.” Statutes, ordinances, and regulations refer to
written law through which a State can authorize an official to
speak on its behalf. “Custom” and “usage” encompass “persistent
practices of state officials” that are “so permanent and well
settled” that they carry “the force of law.” Adickes , 398
U. S., at 167–168. So a city manager like Freed would be
authorized to speak for the city if written law like an ordinance
empowered him to make official announcements. He would also have
that authority even in the absence of written law if, for instance,
prior city managers have purported to speak on its behalf and have
been recognized to have that authority for so long that the
manager’s power to do so has become “permanent and well settled.” Id. , at 168. And if an official has authority to speak for
the State, he may have the authority to do so on social media even
if the law does not make that explicit.

															Determining the scope of an official’s power
requires careful attention to the relevant statute, ordinance,
regulation, custom, or usage. In some cases, a grant of authority
over particular subject matter may reasonably encompass authority
to speak about it officially. For example, state law might grant a
high-ranking official like the director of the state department of
transportation broad responsibility for the state highway system
that, in context, includes authority to make official announcements
on that subject. At the same time, courts must not rely on
“ ‘excessively broad job descriptions’ ” to conclude that
a government employee is authorized to speak for the State. Kennedy v. Bremerton School Dist. , 597 U.S. 507, 529
(2022) (quoting Garcetti , 547 U. S., at 424). The
inquiry is not whether making official announcements could fit within the job description; it is whether making official
announcements is actually part of the job that the State
entrusted the official to do.

															In sum, a defendant like Freed must have actual
authority rooted in written law or longstanding custom to speak for
the State. That authority must extend to speech of the sort that
caused the alleged rights deprivation. If the plaintiff cannot make
this threshold showing of authority, he cannot establish state
action.

															B

															For social-media activity to constitute state
action, an official must not only have state authority—he must also
purport to use it. Griffin , 378 U. S., at 135. State
officials have a choice about the capacity in which they choose to
speak. “[G]enerally, a public employee” purports to speak on behalf
of the State while speaking “in his official capacity or” when he
uses his speech to fulfill “his responsibilities pursuant to state
law.” West , 487 U. S., at 50. If the public employee
does not use his speech in furtherance of his official
responsibilities, he is speaking in his own voice.

															Consider a hypothetical from the offline world.
A school board president announces at a school board meeting that
the board has lifted pandemic-era restrictions on public schools.
The next evening, at a backyard barbecue with friends whose
children attend public schools, he shares that the board has lifted
the pandemic-era restrictions. The former is state action taken in
his official capacity as school board president; the latter is
private action taken in his personal capacity as a friend and
neighbor. While the substance of the announcement is the same, the
context—an official meeting versus a private event—differs. He
invoked his official authority only when he acted as school board
president.

															The context of Freed’s speech is hazier than
that of the hypothetical school board president. Had Freed’s
account carried a label ( e.g. , “this is the personal page of
James R. Freed”) or a disclaimer ( e.g. , “the views expressed
are strictly my own”), he would be entitled to a heavy (though not
irrebuttable) presumption that all of the posts on his page were
personal. Markers like these give speech the benefit of clear
context: Just as we can safely presume that speech at a backyard
barbeque is personal, we can safely presume that speech on a
“personal” page is personal (absent significant evidence indicating
that a post is official).[ 2 ]
Conversely, context can make clear that a social-media account
purports to speak for the government—for instance, when an account
belongs to a political subdivision ( e.g. , a “City of Port
Huron” Facebook page) or is passed down to whomever occupies a
particular office ( e.g. , an “@PHuronCityMgr” Instagram
account). Freed’s page, however, was not designated either
“personal” or “official,” raising the prospect that it was “mixed
use”—a place where he made some posts in his personal capacity and
others in his capacity as city manager.

															Categorizing posts that appear on an ambiguous
page like Freed’s is a fact-specific undertaking in which the
post’s content and function are the most important considerations.
In some circumstances, the post’s content and function might make
the plaintiff ’s argument a slam dunk. Take a mayor who makes
the following announcement exclusively on his Facebook page:
“Pursuant to Municipal Ordinance 22.1, I am temporarily suspending
enforcement of alternate-side parking rules.” The post’s express
invocation of state authority, its immediate legal effect, and the
fact that the order is not available elsewhere make clear that the
mayor is purporting to discharge an official duty. If, by contrast,
the mayor merely repeats or shares otherwise available
information—for example, by linking to the parking announcement on
the city’s webpage—it is far less likely that he is purporting to
exercise the power of his office. Instead, it is much more likely
that he is engaging in private speech “relate[d] to his public
employment” or “concern[ing] information learned during that
employment.” Lane , 573 U. S., at 238.

															Hard-to-classify cases require awareness that an
official does not necessarily purport to exercise his authority
simply by posting about a matter within it. He might post
job-related information for any number of personal reasons, from a
desire to raise public awareness to promoting his prospects for
reelection. Moreover, many public officials possess a broad
portfolio of governmental authority that includes routine
interaction with the public, and it may not be easy to discern a
boundary between their public and private lives. Yet these
officials too have the right to speak about public affairs in their
personal capacities. See, e . g ., id ., at
235–236. Lest any official lose that right, it is crucial for the
plaintiff to show that the official is purporting to exercise state
authority in specific posts. And when there is doubt, additional
factors might cast light—for example, an official who uses
government staff to make a post will be hard pressed to deny that
he was conducting government business.

															One last point: The nature of the technology
matters to the state-action analysis. Freed performed two actions
to which Lindke objected: He deleted Lindke’s comments and blocked
him from commenting again. So far as deletion goes, the only
relevant posts are those from which Lindke’s comments were removed.
Blocking, however, is a different story. Because blocking operated
on a page-wide basis, a court would have to consider whether Freed
had engaged in state action with respect to any post on which
Lindke wished to comment. The bluntness of Facebook’s blocking tool
highlights the cost of a “mixed use” social-media account: If
page-wide blocking is the only option, a public official might be
unable to prevent someone from commenting on his personal posts
without risking liability for also preventing comments on his
official posts.[ 3 ] A public
official who fails to keep personal posts in a clearly designated
personal account therefore exposes himself to greater potential
liability.

															*  *  *

															The state-action doctrine requires Lindke to
show that Freed (1) had actual authority to speak on behalf of
the State on a particular matter, and (2) purported to
exercise that authority in the relevant posts. To the extent that
this test differs from the one applied by the Sixth Circuit, we
vacate its judgment and remand the case for further proceedings
consistent with this opinion.

															It is so ordered. Notes 1 Because local governments
are subdivisions of the State, actions taken under color of a local
government’s law, custom, or usage count as “state” action for
purposes of §1983. See Monell v. New York City Dept. of
Social Servs. , 436 U.S.
658 , 690–691 (1978). And when a state or municipal employee
violates a federal right while acting “under color of law,” he can
be sued in an individual capacity, as Freed was here. 2 An official cannot
insulate government business from scrutiny by conducting it on a
personal page. The Solicitor General offers the particularly clear
example of an official who designates space on his nominally
personal page as the official channel for receiving comments on a
proposed regulation. Because the power to conduct
notice-and-comment rulemaking belongs exclusively to the State, its
exercise is necessarily governmental. Similarly, a mayor would
engage in state action if he hosted a city council meeting online
by streaming it only on his personalFacebook page. By contrast, a
post that is compatible with either a “personal capacity” or
“official capacity” designation is “personal” if it appears on a
personal page. 3 On some platforms, a
blocked user might be unable even to see the blocker’s
posts. See, e . g ., Garnier v. O’Connor-Ratcliff , 41 F. 4th, 1158, 1164 (CA9 2022)
(noting that “on Twitter, once a user has been ‘blocked,’ the
individual can neither interact with nor view the blocker’s Twitter
feed”); Knight First Amdt. Inst. at Columbia
Univ . v. Trump , 928 F.3d 226, 231 (CA2 2019) (noting
that a blocked user is unable to see, reply to, retweet, or like
the blocker’s tweets).

Summary: The Supreme Court held that when a government official posts about job-related topics on social media, their speech is attributable to the state only if the official had the authority to speak on the state's behalf and purported to exercise that authority when speaking on social media. In this case, James Freed, the city manager of Port Huron, Michigan, deleted comments and blocked users on his Facebook page, including Kevin Lindke, who sued Freed for violating his right to free speech. The Court ruled that Freed's actions were not state action and that Lindke must show that Freed had the authority to speak for the state and intended to do so when silencing Lindke's speech. The case was sent back to the lower court to apply this test.