Regulation of Camera Lighting in Public Meetings Does Not Impede First Amendment Rights

Introduction

Kamryn Randle v. Ladel Lewis, decided by the Sixth Circuit on May 1, 2025 (No. 24-1888), addressed whether a city council may enforce a rule prohibiting overly bright camera lights without violating the First Amendment rights of a meeting attendee. Plaintiff-Appellant Randle, acting as support staff for a councilmember, was instructed to turn off the light on her video camera during a Flint City Council session because it was causing discomfort to a councilwoman. Randle sued, alleging violations of her rights of access and expression under the First Amendment and conspiracy under 42 U.S.C. § 1985, along with related state-law claims. The Sixth Circuit affirmed the district court’s summary judgment for the defendants, holding that the enforcement of a content-neutral disorderly-conduct rule was permissible in a designated public forum.

Summary of the Judgment

The Sixth Circuit held that Randle’s First Amendment access claim failed because, even if restricting her bright light implicated access, the rule against disruptive lighting was a content-neutral, nondiscriminatory measure reasonably related to the government’s interest in an orderly meeting.
The court held that Randle’s First Amendment expression claim failed both because recording alone is not “speech” protected in that context and—if it were—a time/place/manner restriction on bright lights in a designated public forum must only be content-neutral, narrowly tailored to serve a significant interest, and leave open alternative channels.
The conspiracy claim under § 1985 fell with the underlying First Amendment claims, and the court declined supplemental jurisdiction over state-law counts.
The decision affirms summary judgment because Randle offered no Rule 56(d) affidavit to seek further discovery, and no genuine dispute of material fact remained.

Analysis

Precedents Cited

S.H.A.R.K. v. Metro Parks Serving Summit County, 499 F.3d 553 (6th Cir. 2007) – established a three-step test for access restrictions: identify the rule invoked, state the government interest, and apply the appropriate level of scrutiny.
Lowery v. Jefferson County Board of Education, 586 F.3d 427 (6th Cir. 2009) – recognized that disorderly-conduct rules in limited public forums must be content-neutral and reasonably relate to significant government interests.
Ward v. Rock Against Racism, 491 U.S. 781 (1989) – held that time/place/manner regulations in public forums need only be content-neutral, narrowly tailored, and leave open ample alternatives.
Whiteland Woods, L.P. v. Township of West Whiteland, 193 F.3d 177 (3d Cir. 1999) – permitted a ban on video cameras in planning-commission meetings so long as alternative recording methods remained available.
Rice v. Kempker, 374 F.3d 675 (8th Cir. 2004) – unanimously held that courtroom bans on videotaping do not violate the First Amendment right of public access.
Scott v. Harris, 550 U.S. 372 (2007) – clarified that when a party’s version of events is blatantly contradicted by video evidence, courts need not adopt it on summary judgment.

Legal Reasoning

1. Freedom of Access
The court recognized Randle’s qualified First Amendment right to attend and record council proceedings. Under the S.H.A.R.K. framework, the city invoked its rule against “disorderly conduct,” which is content-neutral and applies to all attendees. The council’s interests—preserving order and accommodating a councilmember’s sensitivity to bright lights—were legitimate. The measure (asking Randle to turn off only her camera’s light) was reasonably related to those interests and did not burden substantially more access than necessary. Alternative means of access remained: the council’s own livestream, personal audio or note-taking, or a less-bright device.

2. Freedom of Expression
Randle’s claim rested solely on her recording activity, not on speaking at the meeting or distributing materials later. The panel emphasized that mere recording does not automatically equate to protected “speech.” Even assuming it did, a city council chamber is a designated public forum in which time/place/manner regulations must be content-neutral, narrowly tailored to significant interests, and leave open alternatives. The bright-light prohibition satisfied those criteria.

3. Summary Judgment Standard
The district court treated the defendants’ motion as one under Rule 56 after considering videos and transcripts. Randle did not file a Rule 56(d) affidavit requesting more discovery, so she forfeited any argument that summary judgment was premature. With undisputed evidence—especially video footage—the court properly granted summary judgment.

Impact

This decision clarifies that:

Legislative bodies may enforce content-neutral rules against disruptive recording devices at public meetings without violating First Amendment rights of access or expression.
Attendees cannot challenge narrow, manner-based restrictions merely because they wish to use particular equipment (e.g., bright lights) when reasonable alternatives exist.
Video and body-cam footage can be dispositive on summary judgment when they directly contradict a plaintiff’s assertions.
Plaintiffs must invoke Rule 56(d) if they wish to defer summary judgment and seek additional discovery.

Future litigants will find in Randle that courts apply established public-forum tests rigorously and will not tolerate pretextual claims of First Amendment infringement where orderly-conduct rules are plainly invoked.

Complex Concepts Simplified

Designated Public Forum: A government space (like a city-council chamber) opened for certain expressive activities, where reasonable time/place/manner rules are allowed.
Content-Neutral Rule: A regulation that applies irrespective of the message conveyed, judged by “who” or “what,” not by “what is said.”
S.H.A.R.K. Test: A three-step inquiry—(1) identify the rule, (2) articulate the government interest, (3) apply the appropriate scrutiny (rational basis for nonselective rules; strict scrutiny if selective).
Rule 56(d) Affidavit: A formal request in federal court saying, “I need more discovery before you decide summary judgment,” with specific reasons and facts to be uncovered.
Summary Judgment: A ruling when no genuine factual dispute exists and one side is entitled to win under the law; the court views evidence in the non-movant’s favor unless contradicted by indisputable video or documents.

Conclusion

Kamryn Randle v. Ladel Lewis reaffirms that content-neutral, narrowly tailored manner restrictions at public meetings—such as limiting bright camera lights—do not infringe First Amendment rights of access or expression. The decision underscores the importance of alternative recording means, careful forum analysis, and proper procedural steps (like Rule 56(d)) when opposing summary judgment. It provides clear guidance to legislative bodies, municipal attorneys, and First Amendment practitioners on preserving orderly public forums without trampling constitutional guarantees.