Scarborough v. Frederick Cnty. Sch. Bd. 517 F. Supp. 3d 569 (W.D. Va. 2021) It is unclear what might be relevant to a government official's decision to ban an individual from their Facebook page besides that individual's activity on the Facebook page in question. That activity is apparent without predeprivation procedures. It is simply not clear how predeprivation procedures might meaningfully reduce the risk of erroneous deprivation. Id. In other words, the court held that predeprivation procedures would likely not change the government employee's decision to block or not block an individual on a social-media account because there would be no additional information to gather and examine before any decision is made. Finally, the court examined the government's interest in not providing additional predeprivation procedural requirements. The court found that "government officials have at least a reasonably strong interest in moderating discussion on their Facebook pages in an expeditious manner." Id. For example, the court noted that allowing a socialmedia commenter to continuously post inappropriate comments pending a predeprivation review process could prohibit a government official from using the online forum for its intended purpose, thereby infringing on his First Amendment rights. Id. Adding to this, the court found that "[g]iven the prevalence of online ‘trolls,’ this is no mere hypothetical risk." Id. (citation omitted). The court ultimately concluded: "Given (1) the relatively weak First Amendment interest at issue, (2) the uselessness of any predeprivation procedures in this context, and (3) the degree to which imposing predeprivation procedures here would impinge on the government's legitimate interest, the ... Plaintiff was not entitled to any form of predeprivation hearing before being banned from [the government official's] Facebook page." Id. at 721– 22. 584 The court agrees with the analysis in Davison , as the facts in that case were almost identical to those presented here. Scarborough alleges that when Sovine and Angelo blocked her on Twitter, she called FCPS's attorney and was unblocked on the same day. Scarborough also notes that she never "tweeted" or "commented" at Sovine's and Angelo's Twitter pages; she merely "followed" their public Twitter accounts. (2d Am. Compl. ¶¶ 21–22.) While the court found that Scarborough stated a plausible First Amendment violation on these facts, the court also recognizes, as the court did in Davison , that Scarborough's First Amendment interests as it relates to those Twitter accounts are relatively weak. Unlike Facebook, Scarborough did not publish her views on Twitter. Moreover, the court agrees that predeprivation procedures—such as a hearing or a review process —in the context of social media would not significantly decrease the risk of erroneous First Amendment deprivations. When the only information the government official possesses in deciding to block a person on Twitter is the fact that the individual follows him on Twitter, it is unclear how any predeprivation process would influence the government arbiter *584 or affect the outcome. Finally, the court concludes that the government has a strong interest in the ability to quickly remove unlawful speech from socialmedia platforms before awaiting the results of any predeprivation review. For example, if a government official received a death threat or other violent threat on social media, it is imperative that government officials possess flexibility under the law to promptly remove such comments. Upon balancing the relevant factors, the court concludes that it cannot grant Scarborough the relief she seeks regarding predeprivation process against Defendants Sovine and Angelo. Scarborough, however, seemingly also seeks postdeprivation review in Count II (e.g. , the ability to appeal the decision to block her). As explained above, Scarborough was unblocked 11