Independent Decisionmaker Doctrine Refined: Eleventh Circuit Clarifies § 1983 Causation When Police Issue Trespass Warnings and Make Arrests

Introduction

In Olivia Coley-Pearson v. Emily Misty Martin, No. 23-13249 (11th Cir. Oct. 14, 2025), the Eleventh Circuit affirmed summary judgment for Coffee County Elections Supervisor Misty Martin and Coffee County in a § 1983 suit alleging First and Fourth Amendment violations. The decision crystallizes a key causation principle in § 1983 litigation: when an independent, deliberative decisionmaker stands between a defendant’s actions and the plaintiff’s alleged constitutional injury, the causal chain is broken absent evidence of coercion, deception, extraordinary influence, chain-of-command control, or comparable undermining of independent judgment.

The dispute arose from events during Georgia’s 2020 early voting. Plaintiff Olivia Coley-Pearson, a civic figure committed to assisting voters, had a heated exchange at a Coffee County polling place with Elections Supervisor Misty Martin over the operation of a new ballot scanner. Police were called. Later that day, after Martin asked for a ban, a City of Douglas police sergeant (Joe Stewart) issued Coley-Pearson a criminal trespass warning barring her from county polling places and then arrested her when she refused to leave.

Coley-Pearson sued Martin and the County, asserting:

First Amendment violations based on the breadth and alleged vagueness of the criminal trespass warning and its effect on her voter-assistance activity; and
Fourth Amendment false arrest arising from her arrest for refusing to leave after receiving the trespass warning.

The district court granted summary judgment to Martin and the County because a City of Douglas officer—not Martin—authored the trespass warning and made the arrest. The Eleventh Circuit affirmed on the single, dispositive ground of causation: the intervening actions of Sergeant Stewart, a deliberative and autonomous decisionmaker, severed the causal chain between Martin’s conduct and the injuries alleged by Coley-Pearson.

Summary of the Opinion

Writing for a unanimous panel (Judges Jill Pryor, Branch, and Hull), Judge Branch held:

Section 1983 requires an “affirmative causal connection” between the defendant’s acts/omissions and the constitutional deprivation.
The chain of causation is broken if an intervening actor’s decision is “deliberative and autonomous”—i.e., the actor retains independent judgment and free will—not coerced, deceived, or subordinated within a chain of command.
On this record, Sergeant Stewart independently investigated, drafted the criminal trespass warning using his own language, and made the arrest based on his own judgment and observations; therefore, Martin did not cause the asserted First or Fourth Amendment harms.
Because Martin did not inflict a constitutional harm, municipal liability against Coffee County also fails (even assuming Martin acted as a final policymaker). City of Los Angeles v. Heller controls.
The court declined to reach the merits of the First Amendment challenges (e.g., alleged vagueness or prior restraint) because causation alone resolved the appeal.

Analysis

Precedents Cited and Their Role in the Decision

Dixon v. Burke County, 303 F.3d 1271 (11th Cir. 2002): The cornerstone precedent. Dixon held that a defendant does not cause a plaintiff’s harm when a “deliberative and autonomous decision-maker” stands in the causal chain. In Dixon, a district attorney’s suggestion to select a white male for a school board vacancy did not cause the plaintiff’s exclusion because the grand jury and a judge independently made the ultimate appointment. The Eleventh Circuit relies on Dixon’s “free, independent, and volitional acts” formulation and its illustrations of when intervening decisionmakers do not break causation (e.g., where there is coercion or extraordinary influence).
Brown v. City of Huntsville, 608 F.3d 724 (11th Cir. 2010): Applied Dixon’s causation logic in a Fourth Amendment context. A non-arresting officer who told the arresting officer to make the arrest was not the cause because he lacked chain-of-command authority and had no active, personal participation in the arrest. This maps closely onto Martin’s role relative to Sergeant Stewart.
Carruth v. Bentley, 942 F.3d 1047 (11th Cir. 2019): Reaffirmed that where a board exercises independent judgment, allegations must impugn the board’s independence to maintain causation. The panel cites Carruth to underscore that plaintiffs must plead and prove facts undermining the intermediary’s independence.
Barts v. Joyner, 865 F.2d 1187 (11th Cir. 1989); Jordan v. Mosley, 487 F.3d 1350 (11th Cir. 2007); Carter v. City of Melbourne, 731 F.3d 1161 (11th Cir. 2013): These cases delineate circumstances that preserve causation despite an intervenor—e.g., deception, undue pressure, knowingly supplying false information, or where the intervenor relies entirely on the defendant’s account without investigation. The court uses them to craft a practical checklist of what defeats the “independent decisionmaker” break in causation.
Keating v. City of Miami, 598 F.3d 753 (11th Cir. 2010): Supervisors within the chain of command are liable for directing their subordinates’ actions. The panel contrasts this with Martin’s position: she was not in Sergeant Stewart’s chain of command.
Jackson v. Sauls, 206 F.3d 1156 (11th Cir. 2000) and Zahrey v. Coffey, 221 F.3d 342 (2d Cir. 2000): Address the tension between proximate cause/foreseeability and intervening independent judgment. The court resolves this tension by treating the intervening act as foreseeable (and thus preserving causation) only if it was not an exercise of truly independent judgment—e.g., due to pressure or misleading information.
Monell-related authorities: Chabad Chayil, Inc. v. School Board of Miami-Dade County, 48 F.4th 1222 (11th Cir. 2022) (final policymaker theory) and City of Los Angeles v. Heller, 475 U.S. 796 (1986) (no municipal liability absent underlying constitutional harm by the putative policymaker).
Standards and general causation doctrine: Troupe v. Sarasota County, 419 F.3d 1160 (11th Cir. 2005) (affirmative causal connection requirement); LaMarca v. Turner, 995 F.2d 1526 (11th Cir. 1993) (cause vs. contributing factor); Ziegler v. Martin County School District, 831 F.3d 1309 (11th Cir. 2016) and Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standards).

Legal Reasoning

1) The governing causation rule

Section 1983 liability turns on an “affirmative causal connection” between the defendant’s conduct and the constitutional injury. That chain is broken when an intervening actor—here, a police sergeant—exercises “deliberative and autonomous” judgment. The court provides a concrete, practitioner-friendly framework for evaluating when an intervenor is independent and when not.

An intervenor is not a deliberative, autonomous decisionmaker if:

The defendant coerced or exercised extraordinary influence over the intervenor (Dixon).
The defendant deceived or unduly pressured the intervenor (Barts).
The defendant was in the intervenor’s chain of command or actively directed/participated in the act (Brown; Keating).
The intervenor relied entirely on the defendant’s story and failed to conduct any independent investigation (Jordan; Carter).

Conversely, where an intervenor investigates independently, uses their own judgment and language, is outside the defendant’s chain of command, and is not misled or pressured, the intervenor’s action is treated as the immediate cause, breaking § 1983 causation as to the upstream official.

2) Application to the First Amendment claim (criminal trespass warning)

The City of Douglas sergeant authored and issued the trespass warning. The record showed:

He interviewed nine witnesses (beyond Martin) about the “disturbance.”
He testified that the warning’s language “entirely came from” him.
Martin left the “scope, breadth, and duration” to the city officers.

Although Martin asked that Coley-Pearson be banned, the sergeant had options under Georgia law and chose—after investigation—to issue an “indefinite” trespass warning. That independent choice broke causation. The court expressly noted that while Martin’s request was a necessary predicate under O.C.G.A. § 16-7-21(b)(3) (trespass after notice from an authorized representative), necessity alone does not negate the officer’s independent judgment.

3) Application to the Fourth Amendment claim (arrest)

The arrest likewise flowed from the sergeant’s independent judgment:

He stated the arrest decision “rested entirely with” him.
Video showed he observed Coley-Pearson’s refusal to comply post-warning.
While officers asked Martin (as property controller) whether she wanted enforcement of trespass, that request did not convert her into a commander within the arresting officer’s chain of command.

Under Brown, even an explicit request to make an arrest does not establish § 1983 causation unless the requester has command authority or actively participates in the arrest in a way that overrides the officer’s independent judgment. None of those conditions were present here.

4) Rejection of plaintiff’s “manipulation” theory

Coley-Pearson argued Martin falsely manufactured a disruption and supplied false facts. The record undercut those assertions:

Multiple witnesses did not contradict that a disturbance occurred; plaintiff admitted she raised her voice.
The arrest was based on plaintiff’s refusal to depart after notice, which the sergeant personally observed.
Martin’s statement—“If I have to say I feel threatened … Because I do … she was all up in my face”—was not contradicted by record evidence.

Without evidence of deception, undue pressure, or extraordinary influence, the intervenor’s independence stood intact.

5) Foreseeability versus independent judgment

The court addressed the tension: defendants are typically liable for foreseeable consequences, including foreseeable intervening acts. But where an intervenor’s act is an exercise of “truly independent judgment,” foreseeability yields to the independent decisionmaker doctrine. Only where independence is undermined (pressure, misleading information, chain-of-command direction) does foreseeability preserve causation. The court’s approach aligns with Zahrey and the Eleventh Circuit’s own Barts/Jordan/Carter line.

6) Municipal liability (final policymaker theory)

Even assuming the Elections Supervisor was a final policymaker for the County, Heller forecloses municipal liability where the policymaker “inflicted no constitutional harm.” Because Martin did not cause the trespass warning or the arrest, the County cannot be liable for those actions. The opinion also notes the structural separation: the arresting officer was a City of Douglas officer, not a County agent.

Impact

This opinion meaningfully refines and operationalizes the “independent decisionmaker” break in § 1983 causation across First and Fourth Amendment contexts. Anticipated effects include:

Pleading and proof in § 1983 cases: Plaintiffs must marshal concrete facts that impugn the intermediary’s independence—e.g., that the defendant supplied knowingly false facts, applied undue pressure, had chain-of-command control, or that the intermediary failed to perform any independent investigation. Bare assertions that the defendant asked for enforcement action will not suffice.
Election administration: Election officials can request law enforcement intervention against disruptive behavior without automatically incurring § 1983 liability for trespass warnings or arrests. Liability risk rises if officials mislead officers, pressure them unduly, or effectively commandeer the decision (e.g., through chain-of-command or active direction).
Law enforcement practice: Officers who independently investigate, use their own judgment, and document the basis for enforcement decisions help maintain the independence that insulates upstream officials from causation and themselves from derivative municipal exposure.
Municipal liability strategy: Plaintiffs relying on final policymaker theories must show that the policymaker’s decisions—not a separate city officer’s independent choices—caused the constitutional harm. Organizational separations (city vs. county) matter.
Foreseeability arguments narrowed: Plaintiffs cannot rely on generalized foreseeability to bridge causation where an officer’s “truly independent” judgment intervenes. They must show independence was compromised.

Complex Concepts Simplified

Affirmative causal connection (Section 1983): You must show the defendant’s conduct directly caused the constitutional violation, not just that it was part of the background or made the violation more likely.
Deliberative and autonomous decisionmaker: A person who makes their own decision after thinking it through, free from coercion, deception, or orders. If such a person’s decision causes the harm, the earlier actor typically isn’t liable.
Breaking the causal chain: When the intervenor’s independent decision becomes the true cause of the harm, liability doesn’t “reach back” to the person who merely asked for action.
Chain of command: If the defendant supervises the intervenor and directs them to act, the intervenor’s independence is compromised and causation can persist.
Undue pressure/deception: Heavy pressure, threats, or knowingly false information provided to the intervenor overrides independent judgment and preserves causation.
Monell/final policymaker: A local government is liable only when a policy or a decision by a final policymaker causes a constitutional violation. If the policymaker didn’t cause the harm, the municipality isn’t liable.
Georgia criminal trespass (O.C.G.A. § 16-7-21(b)(3)): A person commits trespass by remaining after notice from an authorized representative to depart. An official’s request may be necessary to trigger notice, but the officer still independently decides whether to issue a warning or make an arrest.

Practical Guidance for Litigants

For plaintiffs: To maintain causation past an intervening officer, develop evidence that:
- The officer took no independent steps (no witness interviews, no independent observations);
- The defendant supplied false facts or omitted exculpatory information knowingly;
- The defendant had supervisory authority over the officer or actively directed the specific enforcement action; or
- The officer’s decision was otherwise not a product of independent, free will.
For government defendants: Preserve and present evidence of the officer’s independent investigation and discretion (reports, video, witness statements, independent observations, authorship of documents) and the absence of chain-of-command relationships.
For courts: The opinion provides a factor set to assess intervenor independence and signals that causation can be dispositive without reaching challenging merits questions (e.g., prior restraint, forum analysis, vagueness).

Conclusion

Coley-Pearson v. Martin reinforces and refines a pivotal doctrine in § 1983: when a deliberative, autonomous decisionmaker intervenes—here, a police sergeant who independently investigated, drafted the trespass warning, and decided to arrest—the causal chain to an upstream official breaks absent evidence that the intervenor’s independence was compromised by coercion, deception, extraordinary influence, chain-of-command control, or exclusive reliance on the defendant’s account.

The ruling has immediate consequences for litigation strategy in the Eleventh Circuit. Plaintiffs must plead and prove facts undermining the independence of intervening actors to reach earlier officials; defendants should document and highlight the autonomy of intervening decisions. In the municipal context, Heller forecloses liability where the alleged policymaker did not cause the underlying constitutional injury.

By clarifying the independent decisionmaker doctrine and providing concrete examples of when it does and does not apply, the Eleventh Circuit offers a clear, structured causation analysis that will guide future First and Fourth Amendment § 1983 cases, particularly those involving election administration and law enforcement responses at polling places.