Snelling v. Gregory

3 Citing cases

  1. Harris v. Sowers

    2:16-cv-888 (S.D. Ohio Nov. 16, 2022)   Cited 1 times

    Though “threats alone can constitute an adverse action if the threat is capable of deterring a person of ordinary firmness from engaging in protected conduct,” Hill v. Lappin, 630 F.3d 468, 475 (6th Cir. 2010), “courts have generally held that vague threats of unspecified harm do not constitute adverse actions.” Snelling v. Gregory, No. 1:17-cv-P41, 2017 WL 2602591, at *3 (W.D. Ky. June 14, 2017) (

  2. Harris v. Sowers

    Case NO. 2:16-cv-888 (S.D. Ohio Nov. 20, 2020)   Cited 4 times

    The magistrate judge correctly concluded that even assuming that Hays made the above statement, it was too vague to deter a person of ordinary firmness from engaging in protected conduct. See Snelling v. Gregory, No. 1:17-cv-P41, 2017 WL 2602591, at *3 (W.D. Ky. June 14, 2017)(noting that "courts have generally held that vague threats of unspecified harm do not constitute adverse actions); see also Hardy v. Adams, No. 16-2055, 2018 WL 3559190, at *3 (6th Cir. Apr. 13, 2018)("The alleged threat by Adams that she would make Hardy's life 'hell' is simply too vague to pass this threshold"). The magistrate judge correctly concluded that Hays' statement, even assuming it was made, did not arise to the level of an adverse action.

  3. Harris v. Sowers

    Civil Action 2:16-cv-888 (S.D. Ohio Feb. 11, 2020)   Cited 2 times

    However, "courts have generally held that vague threats of unspecified harm do not constitute adverse actions." Snelling v. Gregory, No. 1:17-cv-P41, 2017 WL 2602591, at *3 (W.D. Ky. June 14, 2017) (collecting cases); see also Hardy v. Adams, No. 16-2055, 2018 WL 3559190, at *3 (6th Cir. Apr. 13, 2018) ("The alleged threat by Adams that she would make Hardy's life 'hell' is simply too vague to pass this threshold."); Kyle v. Skipper, No. 1:19-cv-353, 2019 WL 3729384, at *5 (W.D. Mich. Aug. 8, 2019) ("A specific threat of harm may satisfy the adverse-action requirement if it would deter a person of ordinary firmness from exercising his or her First Amendment rights" and "[t]he threat Plaintiff alleges—"you will regret it"—is too vague and non-specific to deter a person of ordinary firmness from engaging in protected conduct") (citations omitted) (emphasis added). Here, the Verified Amended Complaint describes Defendant Hays' threat as follows: