Patricia Manson v. Little Rock Newspapers, Inc., Doing Bus. as Arkansas Democrat-Gazette, 200 F.3d 1172 (8th Cir. 2000). · Go Syfert
Patricia Manson v. Little Rock Newspapers, Inc., Doing Bus. as Arkansas Democrat-Gazette, 200 F.3d 1172 (8th Cir. 2000). Cases Citing This Book View Copy Cite
“simply put, the defendant is a private entity, not a governmental entity, and thus is legally incapable of violating anyone's first amendment rights.”
9 citation events (9 in the last 25 years) across 7 distinct courts.
Strongest positive: Heather Smith v. BlueCross BlueShield of Tennessee
Top citers, strongest first. 7 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Heather Smith v. BlueCross BlueShield of Tennessee
unknown court · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
simply put, the defendant is a private entity, not a governmental entity, and thus is legally incapable of violating anyone's first amendment rights.
discussed Cited as authority (rule) Hargrove v. City of San Diego
S.D. Cal. · 2021 · confidence medium
As to the second 15 requirement, NBC7 “is a private entity, not a governmental entity, and thus is legally 16 incapable of violating anyone’s First Amendment rights.” Manson v. Little Rock 17 Newspapers, Inc., 200 F.3d 1172, 1173 (8th Cir. 2000).
discussed Cited as authority (rule) Federal Agency of News LLC v. Facebook, Inc.
N.D. Cal. · 2020 · confidence medium
Cal. 1 Jan. 17, 2008) (citing Manson v. Little Rock Newspapers, Inc., 200 F.3d 1172, 1173 (8th Cir. 2 2000)). 3 Indeed, courts have previously rejected attempts to apply the First Amendment to 4 Facebook, a “corporation organized and existing under the laws of the State of Delaware,” FAC 5 ¶ 7.
discussed Cited as authority (rule) Grinzi v. San Diego Hospice Corp.
Cal. Ct. App. · 2004 · confidence medium
App. 292 [ 484 S.E.2d 840, 843 ] [claim of wrongful discharge failed because conduct in private employment is not protected by the Constitution]; Barr v. Kelso-Burnett Co. (1985) 106 Ill.2d 520 [ 478 N.E.2d 1354, 1357 , 88 Ill.Dec. 628 ] [claim of retaliatory discharge failed because the public policy mandated by the Constitution “is that the power of government, not private individuals, be restricted”]; Edmondson v. Shearer Lumber Products, supra, 75 P.3d 733, 739 [no wrongful termination cause of action against a private employer who terminates the employee because of the exercise of fre…
cited Cited "see" Betty Lou Dossett v. First State Bank
8th Cir. · 2005 · signal: see · confidence high
See Manson v. Little Rock Newspapers, Inc., 200 F.3d 1172, 1173 (8th Cir. 2000).
cited Cited "see" Betty Lou Dossett v. First State Bank, Loomis, Nebraska, Betty Lou Dossett v. Lauritzen Corporation, Doing Business as Financial Services Company
1st Cir. · 2005 · signal: see · confidence high
See Manson v. Little Rock Newspapers, Inc., 200 F.3d 1172, 1173 (8th Cir.2000).
cited Cited "see" Rivoli v. Gannett Co., Inc.
W.D.N.Y. · 2004 · signal: see · confidence high
See Manson, 200 F.3d at 1173 (“Simply put, the defendant is a private entity, not a governmental entity, and thus is legally incapable of violating anyone’s First Amendment rights.
Retrieving the full opinion text from the archive…
Patricia MANSON, Appellant,
v.
LITTLE ROCK NEWSPAPERS, INC., Doing Business as Arkansas Democrat-Gazette, Appellee
99-1943.
Court of Appeals for the Eighth Circuit.
Mar 15, 2000.
200 F.3d 1172
Jack R. Kearney, Little Rock, AR, argued, for Appellant., Leon Holmes, Little Rock, AR, argued, for Appellee.
Bowman, Gibson, Loken.
Cited by 8 opinions  |  Published
BOWMAN, Circuit Judge.

Plaintiff Patricia Manson sued her former employer, Little Rock Newspapers, Inc., asserting claims for age and sex discrimination under federal law as well as claims for wrongful discharge and for outrage under Arkansas law. The District Court [1] dismissed the claim for outrage under Rule 12(b)(6) of the Federal Rules of Civil Procedure. Later, the same court granted summary judgment for the defendant on Manson’s federal claims and on the remaining state-law claim. Manson appeals from the court’s summary-judgment order. [2]

For reversal, Manson argues that summary judgment was inappropriate because there remained genuine issues of material fact on all of her claims. We disagree. Having carefully considered the briefs of the parties and the record on which the District Court granted summary judgment for the defendant, we are satisfied that the grant of summary judgment was proper and must be sustained. Manson has failed to adduce evidence from which a reasonable trier of fact could find that she was discharged on account of her age or sex. In particular, she has not made any showing that the defendant’s stated reasons for discharging her were a pretext for unlawful discrimination. As to her wrongful discharge claim, Manson was an at-will employee. As such, she could be discharged without any reason or for any reason at all except one in violation of a well-established public policy. Although Manson has argued that she was discharged for exercising her First Amendment rights to free speech and free association, the facts do not support her arguments. Simply put, the defendant is a private entity, not a governmental entity, and thus is legally incapable of violating anyone’s First Amendment rights. Any First Amendment rights gennane to this ease are those of the defendant and its newspaper, not those of Manson, a reporter employed in service of the newspaper.

The District Court, at the end of its thorough and well-reasoned twenty-five page opinion, summed up the case as follows:

The evidence in respect to Ms. Manson’s actions and conduct is not in substantial dispute. Based on that conduct and those actions, the fact is that the record shows that the employer had ample and abundant reasons to believe that Ms. Manson was insubordinate, that she failed and, in fact, refused to follow obviously legitimate rules of her employer, that she attempted to tell her employer how to run its newspaper and what to publish, and that she gave away its property (property that it had paid her to produce), resulting in its use by a competitor in an article that was very critical (to say the least) of its [her employer’s] editorial page editor. That will get you “fired” almost anywhere.

We agree.

The order of the District Court is affirmed.

1

. The Honorable H. FRANKLIN WATERS, United States District Judge for the Western District of Arkansas, who presided by designation over this case filed in the Eastern District of Arkansas.

2

. Manson has not appealed the dismissal of her state-law claim for outrage.