Case Explained: Non-Argument Calendar LANA PATRICK v. PASCO COUNTY FLORIDA TAX COLLECTOR

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-16 Docket: 8:25-cv-01690-WFJ-TGW The eleventh-circuit affirmed the district court’s dismissal of Lana Patrick’s § 1983 lawsuit against the Pasco County Tax Collector with prejudice. The court held that Patrick failed to state a valid claim under the First Amendment and abandoned her Florida Sunshine Law claim on appeal. Regarding the First Amendment, the court applied the standard for limited or nonpublic forums, determining that the Tax Collector’s policy prohibiting recording without prior approval was both reasonable in light of the forum’s purpose—specifically to protect confidential citizen information and maintain an orderly environment—and viewpoint neutral. The court further ruled that amendment of the complaint would be futile because the claims failed as a matter of law regardless of factual specificity. Although the district court also dismissed the suit based on res judicata due to a prior lawsuit involving the same incident, the appellate court declined to rule on whether the Tax Collector was in privity with the employee sued in the first action, noting that the failure-to-state-a-claim analysis alone justified the dismissal. Consequently, the judgment of the district court is upheld, and the Tax Collector’s recording policy remains enforceable against Patrick. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.