January 2023 - Parks & Recreation - 33

in part by an unlawful reason (her
dislike of Watkins's singing), " the
federal appeals court held this fact
" does not deprive her of qualified
immunity. " On the contrary, the
appeals court found the applicable
park rules at the time of the incident
" did not clearly rule out a valid
trespass warning for Watkins in
the circumstances facing Sullivan. "
Mixed Motivations
In the opinion of the federal appeals
court, the evidence in this
case indicated: " Sullivan's efforts
to have Watkins removed from the
park were motivated at least in part
by a lawful reason " ; i.e., " Watkins's
unauthorized manner of use
of the pavilion facilities. " Accordingly,
the federal appeals court held
Defendant Sullivan was " entitled
to qualified immunity on a claim
for First Amendment retaliation
because there existed evidence of
both lawful and unlawful motivations
for defendant's conduct. "
Conclusion
The federal appeals court, therefore,
held " Sullivan is entitled to
qualified immunity " and affirmed
the district court's grant of summary
judgment in favor of Defendant
Sullivan.
In addition to this particular
lawsuit, the federal appeals court
cited a number of civil actions
filed by Watkins in federal court,
which had featured this same song
alleging violations of the First
Amendment, including: Watkins
v. Dubreuil, 820 F. App'x 940 (11th
Cir. 2020); Watkins v. Pinnock, 802
F. App'x 450 (11th Cir. 2020); Watkins
v. Cent. Broward Reg'l Park,
799 F. App'x 659 (11th Cir. 2020);
Watkins v. Bigwood, 797 F. App'x
PARK S ANDRECRE AT ION . OR G | J ANUAR Y 2 0 2 3
| Parks & Recreation
33
438 (11th Cir. 2019); Watkins v.
U.S. Postal Emp., 611 F. App'x 549
(11th Cir. 2015).
James C. Kozlowski, J.D., Ph.D., is an Attorney and Professor
emeritus in the School of Sport, Recreation and Tourism
Management at George Mason University (jkozlows@gmu.
edu). Webpage link to an archive of articles (1982 to present):
mason.gmu.edu/~jkozlows/lawarts/artlist.htm.
https://mason.gmu.edu/~jkozlows/lawarts/artlist.htm https://www.dumor.com

January 2023 - Parks & Recreation

Table of Contents for the Digital Edition of January 2023 - Parks & Recreation

January 2023 - Parks & Recreation - Intro
January 2023 - Parks & Recreation - Cover1
January 2023 - Parks & Recreation - Cover2
January 2023 - Parks & Recreation - 1
January 2023 - Parks & Recreation - 2
January 2023 - Parks & Recreation - 3
January 2023 - Parks & Recreation - 4
January 2023 - Parks & Recreation - 5
January 2023 - Parks & Recreation - 6
January 2023 - Parks & Recreation - 7
January 2023 - Parks & Recreation - 8
January 2023 - Parks & Recreation - 9
January 2023 - Parks & Recreation - 10
January 2023 - Parks & Recreation - 11
January 2023 - Parks & Recreation - 12
January 2023 - Parks & Recreation - 13
January 2023 - Parks & Recreation - 14
January 2023 - Parks & Recreation - 15
January 2023 - Parks & Recreation - 16
January 2023 - Parks & Recreation - 17
January 2023 - Parks & Recreation - 18
January 2023 - Parks & Recreation - 19
January 2023 - Parks & Recreation - 20
January 2023 - Parks & Recreation - 21
January 2023 - Parks & Recreation - 22
January 2023 - Parks & Recreation - 23
January 2023 - Parks & Recreation - 24
January 2023 - Parks & Recreation - 25
January 2023 - Parks & Recreation - 26
January 2023 - Parks & Recreation - 27
January 2023 - Parks & Recreation - 28
January 2023 - Parks & Recreation - 29
January 2023 - Parks & Recreation - 30
January 2023 - Parks & Recreation - 31
January 2023 - Parks & Recreation - 32
January 2023 - Parks & Recreation - 33
January 2023 - Parks & Recreation - 34
January 2023 - Parks & Recreation - 35
January 2023 - Parks & Recreation - 36
January 2023 - Parks & Recreation - 37
January 2023 - Parks & Recreation - 38
January 2023 - Parks & Recreation - 39
January 2023 - Parks & Recreation - 40
January 2023 - Parks & Recreation - 41
January 2023 - Parks & Recreation - 42
January 2023 - Parks & Recreation - 43
January 2023 - Parks & Recreation - 44
January 2023 - Parks & Recreation - 45
January 2023 - Parks & Recreation - 46
January 2023 - Parks & Recreation - 47
January 2023 - Parks & Recreation - 48
January 2023 - Parks & Recreation - 49
January 2023 - Parks & Recreation - 50
January 2023 - Parks & Recreation - 51
January 2023 - Parks & Recreation - 52
January 2023 - Parks & Recreation - 53
January 2023 - Parks & Recreation - 54
January 2023 - Parks & Recreation - 55
January 2023 - Parks & Recreation - 56
January 2023 - Parks & Recreation - Cover3
January 2023 - Parks & Recreation - Cover4
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2021
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