Reid, decided today by the Second Circuit (in an opinion by Judge Dennis Jacobs, joined by Judges Amalya Kearse and Jose Cabranes): Plaintiff Roslyn La Liberte spoke at a 2018 city council meeting to oppose California's sanctuary-state law; soon after, a social media activist posted a photo showing the plaintiff with open mouth in front of a minority teenager; the caption was that persons (unnamed) had yelled specific racist remarks at the young man in the photo. [read post]