Scarborough v. Frederick Cnty. Sch. Bd. 517 F. Supp. 3d 569 (W.D. Va. 2021) and Edwards, the court's analysis must cease here. The procedural due process claims against FCSB and Edwards may accordingly proceed. Supreme Court has held that a predeprivation hearing was required where, for example, government officials obtained an injunction forbidding a political rally, ... does not mean that such a hearing was required here, where a public official banned a single individual from a Facebook page for a period of 12 hours." (citation omitted)). In a footnote, the Fourth Circuit affirmed the district court's rejection of the plaintiff's "proposed categorical rule." Davison , 912 F.3d at 688 n.8.5 b. Sovine and Angelo Regarding Sovine and Angelo, Defendants argue that Scarborough "has affirmatively [pleaded] facts which show that she received due process through contact with FCPS'[s] counsel, after which she obtained relief from the asserted actions of Sovine and Angelo." (Id. at 10–11.) As such, Defendants argue that the claim is "implausible on its face." (Id. at 11.) Resolution of this argument requires a more nuanced analysis than Defendants' motion suggests. The district court opinion in Davison v. Loudon County Board of Supervisors is instructive for this claim. The district court addressed the pro se plaintiff's procedural due process claim after the bench trial held in that case. There, the plaintiff had been blocked from a government official's Facebook page for approximately 12 hours. Davison , 267 F. Supp. 3d at 706. Like Scarborough's allegations in the Second Amended Complaint, where she broadly states that the Fourteenth Amendment "requires that the government give ‘notice’ and an ‘opportunity to be heard’ before taking any adverse action against a citizen," (2d Am. Compl. ¶ 32 (emphasis added)), the plaintiff in Davison also "flatly asserted that due process always requires the government to provide a hearing before imposing a prior restraint on speech," Davison , 267 F. Supp. 3d at 719 (first emphasis in original; second emphasis added). In Davison , the court rejected the plaintiff's assertion that a hearing is always required and explained that procedural due process is a flexible concept requiring different protections depending on the circumstances. Id. (citing Cafeteria & Rest. Workers Union, Local 473 v. McElroy , 367 U.S. 886, 895, 81 S.Ct. 1743, 6 L.Ed.2d 1230 (1961) ; Morrissey v. Brewer , 408 U.S. 471, 481, 92 S.Ct. 2593, 33 L.Ed.2d 484 (1972) ) ("The fact that the 5 Because Davison "abandoned that asserted categorical rule on appeal," the Fourth Circuit declined to further consider the plaintiff's procedural due process claim. See id. 583 The court then examined the Supreme Court's balancing test for procedural due process claims: " (1) the nature of the private interest that will be affected, (2) the comparative risk of an erroneous deprivation of that interest with and without additional or substitute procedural safeguards, and (3) the nature and magnitude of any countervailing interest in not providing additional or substitute procedural requirement[s]." Davison , 267 F. Supp. 3d at 720 (internal quotation marks omitted) (quoting *583 Turner v. Rogers , 564 U.S. 431, 444–45, 131 S.Ct. 2507, 180 L.Ed.2d 452 (2011) ; Mathews v. Eldridge , 424 U.S. 319, 335, 96 S.Ct. 893, 47 L.Ed.2d 18 (1976) ). In applying the above analysis, the court first found that the plaintiff's cognizable First Amendment interest in commenting on a government Facebook page was "relatively weak." Id. at 720–21. Second, the court weighed the comparative risk of erroneous deprivations with and without additional predeprivation safeguards. Id. at 721. The plaintiff in that case, like Scarborough, wanted notice that a comment was "targeted and under review." Id. The court held: 10

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