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Gary Mattos, et al., Petitioners v. AFSCME Council 3

Docket 22-567, Supreme Court of the United States (Dec. 20, 2022)
Petitioner Gary Mattos, et al.
Respondent AFSCME Council 3
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Waiver of AFSCME Council 3 of right to - Main Document

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Waiver of AFSCME Council 3 of right to, Main Document (U.S. Dec. 20, 2022)
I DO NOT INTEND TO FILE A RESPONSE to the petition for a writ of certiorari unless one is requested by the Court.
I am filing this waiver on behalf of the following respondent(s): Please check the appropriate box: o I am a member of the Bar of the Supreme Court of the United States.
I am not presently a member ofthe Bar ofthis Court.
O tvtirt Bredhoff & Kaiser P.L.L.C. Firm Address 805 1Sth Street NW, Suite 1000 City & State Washington, DC zip 20005 Phone 2-842-2600 Email karabel l@bredhoff .
Please indicate below the name(s) of the recipient(s) of a copy of this form, No additional certificate of service or cover letter is required.
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Waiver of right of respondent AFSCME - Main Document

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Waiver of right of respondent AFSCME, Main Document (U.S. Dec. 20, 2022)
I DO NOT INTEND TO FILE A RESPONSE to the petition for a writ of certiorari unless one is requested by the Court.
I am filing this waiver on behalf of the following respondent(s): Please check the appropriate box: o I am a member of the Bar of the Supreme Court of the United States.
I am not presently a member ofthe Bar ofthis Court.
O tvtirt Bredhoff & Kaiser P.L.L.C. Firm Address 805 1Sth Street NW, Suite 1000 City & State Washington, DC zip 20005 Phone 2-842-2600 Email karabel l@bredhoff .
Please indicate below the name(s) of the recipient(s) of a copy of this form, No additional certificate of service or cover letter is required.
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Petition for a writ of certiorari filed - Petition

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Petition for a writ of certiorari filed, Petition (U.S. Dec. 15, 2022)
Section 1983 provides that “every person who, un- der color of any statute, ordinance, regulation, custom, or usage, of any State” deprives a citizen of a constitu- tional right “shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.” 42 U.S.C. § 1983.
Section 1983 states, in relevant part: “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State” deprives a citizen of a constitutional right “shall be liable to the party injured in an action at law, suit in equity, or other proper pro- ceeding for redress.” 42 U.S.C. § 1983.
Courts accord an im- munity only when a “tradition of immunity was so firmly rooted in the common law and was supported by such strong policy reasons that Congress would have specifically so provided had it wished to abolish the doctrine when it enacted Section 1983.” Richardson, 521 U.S. at 403 (cleaned up).
Ass’n, 951 F.3d 386, 392 n.2 (6th Cir. 2020); Wholean v. CSEA SEIU Local 2001, 955 F.3d 332, 334-35 (2d Cir. 2020); see also App. 10 (the good-faith defense “protects parties who ‘unwittingly cross [the] line’ into unconstitutionality while acting ‘in reliance on a presumptively valid state law—those who had good cause in other words to call on the gov- ernmental process in the first instance’”) (citing Ogle v. Ohio Civ.
Third, the Owen Court held that “even where some constitutional development could not have been fore- seen by municipal officials, it is fairer to allocate the resulting loss” to the entity that caused the harm ra- ther “than to allow its impact to be felt solely by those whose rights, albeit newly recognized, have been vio- lated.” Id. at 654.
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Petition for a writ of certiorari filed - Appendix

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Petition for a writ of certiorari filed, Appendix (U.S. Dec. 15, 2022)
12 For their part, Plaintiffs maintain they are none- theless entitled to damages under § 1983 because the rule in Janus applies retroactively.
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Petition for a writ of certiorari filed - Proof of Service

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Petition for a writ of certiorari filed, Proof of Service (U.S. Dec. 15, 2022)

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Petition for a writ of certiorari filed - Certificate of Word Count

Document Gary Mattos, et al., Petitioners v. AFSCME Council 3, 22-567, Petition for a writ of certiorari filed, Certificate of Word Count (U.S. Dec. 15, 2022)

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