Facebook Page principally addressed her official responsibilities, a few posts addressed
topics less closely related to her official activities such as her affection for the German
language or pride in becoming an organ donor.
Members of the public, including Davison, “liked” 1 or commented on several of
Randall’s posts on the Chair’s Facebook Page. Each “like” or comment identified the
name of the personal profile or Page of the authoring party. Many of the comments
thanked Randall and the Loudoun Board for representing the public’s interests. Other
posts by members of the public offered feedback on various issues faced by Randall and
the Loudoun Board. E.g., J.A. 427 (stating that “[p]utting recreation in a flood plain is
not a good idea”); J.A. 448 (stating that “more needs to be done with the explosion of
Lyme disease in Loudoun”). And other comments dealt with constituent-specific issues.
E.g., J.A. 415 (constituent stating, in response to post by Randall regarding visit to
Loudoun County’s “Sister City” in Germany, that constituent’s “daughter is interested in
exchange programs”); J.A. 454 (stating that “there [we]re no [snow] plows to be seen” in
a particular neighborhood). Finally, several comments, including a number authored by
Davison, criticized the Loudoun Board, generally, and Randall, in particular, for actions
taken in their official capacities. E.g., J.A. 429–30 (Davison criticizing public school
system budget and expenditures); J.A. 438–39 (member of public criticizing
governmental entity’s inspection of farm, claiming it failed to uncover animal abuse);
1
“‘Liking’ on Facebook is a way for Facebook users to share information with
each other.” Bland v. Roberts, 730 F.3d 368, 385 (4th Cir. 2013).
7