Fields v. City of Philadelphia

Amanda Geraci (plaintiff) attended a protest as a legal observer. While there, Geraci attempted to film an officer arresting a protester. Although Geraci was not interfering with the arrest, another officer physically pushed her up against a pillar and held her there for one to three minutes, preventing her from filming the other officer’s conduct. The officer did not cite Geraci for anything. In a separate incident, college student Richard Fields (plaintiff) witnessed police activity at a house party. Standing on a public sidewalk across the street, Fields photographed the scene with his phone. An officer asked Fields if he liked “taking pictures of grown men” and told Fields to leave. When Fields did not leave, the officer arrested Fields, confiscated the phone, and searched through photos and videos before returning it. The officer ticketed Fields for obstructing a public passage, but the charges were dropped when the officer did not appear at the hearing. Geraci and Fields brought 42 U.S.C. § 1983 claims against the City of Philadelphia (city) (defendant), alleging that the officers had (1) retaliated against them for exercising their First Amendment right to record police officers performing their duties in public and (2) violated their Fourth Amendment right to be free from unreasonable searches and seizures. The district court granted summary judgment to the city on the First Amendment claims. Geraci and Fields appealed.