Daniel Sullivan v. City of Frederick, Maryland, et al.

Three questions are presented:

1. Did the court below err in affirming that a sixmonth criminal investigation of police officer Dan Sullivan, for his off-duty activity of raising money for widows and orphans of fallen officers at a Blue Lives Matter rally, was de minimis harm, thus preventing 42 U.S.C. § 1983 civil rights violation causes of action under the First Amendment for violation of Freedom of Speech, Assembly and for Retaliation?

2. Did the court below err in affirming, at the Motion to Dismiss stage, that Appellant had stated no plausible facts supporting his First Amendment Free Speech or Assembly claims in Counts I, III, IV, or V, and that no Defamation as a matter of fact occurred under Count VII, of his Complaint or Amended Complaint?

3. Do municipalities and their agents maintain quasi-immunity under Monell when they violate a police officer’s due process and First Amendment freedoms, so long as the constitutional harm does not extend to termination or suspension from employment, but may instead include a lengthy criminal investigation?