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Law School Case Brief

Manhattan Cmty. Access Corp. v. Halleck - 139 S. Ct. 1921 (2019)


The Free Speech Clause of the First Amendment constrains governmental actors and protects private actors. To draw the line between governmental and private, the Supreme Court of the United States applies what is known as the state-action doctrine. Under that doctrine, a private entity may be considered a state actor when it exercises a function traditionally exclusively reserved to the State.


Petitioners Manhattan Community Access Corporation ("MCAC") and Manhattan Neighborhood Network ("MMN") operated state-required public access channels in Manhattan, New York. Respondents DeeDee Halleck and Jesus Papoleto Melendez produced a film critical of MNN to be aired on MNN's public access channels. MNN televised the film. MNN later suspended Halleck and Melendez from all MNN services and facilities. Halleck and Melendez filed a lawsuit in federal district court against MCAC and MMN claiming that MNN violated their First Amendment free-speech rights when it restricted their access to the public access channels because of the content of their film. The district court dismissed the claim on the ground that MNN was not a state actor and therefore was not subject to First Amendment constraints on its editorial discretion. The court of appeals reversed in part, concluding that MNN was a state actor subject to First Amendment constraints. MCAC and MMN were granted a writ of certiorari


Were MCAC and MNM, the private operators of public access cable television channels, subject to First Amendment?




The Supreme Court of the United States reversed in part the appellate court's judgment and remanded the matter for further proceedings. The Court ruled that under the state-action doctrine, the operation of public access television channels on a cable system was not a traditional, exclusive public function, and a private entity that opened its property for speech by others was not transformed by that fact alone into a state actor. MNM was not subject to First Amendment constraints on its editorial discretion, and thus Halleck and Melendez failed to state a First Amendment violation.

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