escorting me out. Just posting to let y’all know be careful around our Sheriff, he needs to be in a safe space at all times. (Docket #22-1 at 13). A couple days after the airport incident, Black filed a formal complaint about Clarke with Milwaukee County. (Docket #22-1 at 12). A day or two after that, on January 18, 2017, the Milwaukee County Sherriff’s Office Facebook account posted a link to Black’s complaint and a comment attributed to Clarke: “Next time [Black] or anyone else pulls this stunt on a plane they may get knocked out. The Sheriff . . . does not have to wait for some goof to assault him. He reserves the reasonable right to pre-empt a possible assault.” See (Docket #22-1 at 15).7 The next day, Clarke posted on the same Facebook account a meme, reproduced below, that included a picture of Black and the text “Cheer up, snowflake . . . if Sheriff Clarke were to really harass you, you wouldn’t be around to whine about it.” (Docket #22-1 at 15 and #30 at 10).8 Black did not include copies of the relevant Facebook posts as evidence in opposition to the defendants’ summary judgment motion. The Court therefore relies on reproductions in the complaint, Black’s deposition testimony describing the posts, and the posts themselves, which still appear on Facebook. See Milwaukee County Sheriff’s Office, Facebook (Jan. 18, 2017), https://www.facebook.com/MilwaukeeCountySheriff/posts/10154659733950189; Milwaukee County Sheriff’s Office, Facebook (Jan. 19, 2017), https://www.facebook.com/MilwaukeeCountySheriff/posts/10154663044105189:0. 7 Although the January 19, 2017 post is not directly attributable to Clarke on its face, the defendants do not contest that it was Clarke who made it. (Docket #30 at 9-10). 8 Page 8 of 27 Case 2:17-cv-00156-JPS Filed 01/05/18 Page 8 of 27 Document 39

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