Manhattan Community Access Corp. v. Halleck Case Brief Summary | Law Case Explained

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Manhattan Community Access Corp. v. Halleck | 139 S. Ct. 1921 (2019)

Under the state-action doctrine, the Constitution’s protections generally apply to governmental actors, not private actors. In Manhattan Community Access versus Halleck, Halleck claims her free speech rights have been curtailed by a corporation that operates public-access television channels. But can Halleck convince the court that the private entity silencing her speech is a governmental actor?

New York state law required that cable operators set aside channels for public access. The cable operator was charged with operating the channels unless local government designated another entity. Time Warner was the cable operator in Manhattan. New York City designated Manhattan Community Access, commonly known as the Manhattan Neighborhood Network or M N N, to operate Time Warner’s public-access channels in the area.

DeeDee Halleck and Jesus Papoleto Melendez produced a program criticizing M N N for its neglect of the East Harlem community. The program aired, but M N N later banned the producers from M N N services and facilities.

Halleck and Melendez sued M N N. The producers claimed that M N N violated their free-speech rights when it suspended their access to the channels based on the content of their program. M N N moved to dismiss the complaint, arguing that it wasn’t a governmental actor subject to the First Amendment. The district court agreed and dismissed the complaint. The Second Circuit reversed. The Supreme Court granted cert.

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