April 2023 - Parks & Recreation - 33

so since soliciting was banned. "
In addition, Grant claimed individuals
who continued to engage
in expressing ideas in public were
threatened by police with arrest
for disorderly conduct, failure to
disperse, obstructing public passage
or other crimes in which
charges were later dismissed.
Grant also had alleged " the City
provide
has
failed to
adequate
training, or otherwise update its
training, on how police should respond
to constitutional violations
or solicitations bans, despite having
notice that its training was inadequate
particularly as to the First
Amendment. " In addition, Grant
claimed the City had " no formalized
tracking of complaints or violations,
or data concerning alleged
police interference with free speech
or other activity protected under
the First Amendment. "
In response, the City of Philadelphia
argued Grant had " failed
to prove that the City is the cause
of any injury that he suffered. " The
federal district court acknowledged
that there can be no Section 1983
claim without an underlying constitutional
violation:
It is well-settled that, if there is
no violation in the first place, there
can be no derivative municipal
claim.... If a person has suffered
no constitutional injury at the
hands of the individual police officer,
the fact that the departmental
regulations might have authorized
the use of constitutionally excessive
force is quite beside the point.
In this case, the federal district
court held " Grant's Section 1983
claim fails as a matter of law " because
" no reasonable jury could
conclude that Grant suffered a constitutional
violation. "
Conclusion
Having found no legal basis for
Grant's
trict
claims,
the
court granted
federal disthe
motions
for summary judgment in favor of
the police officers and the City of
Philadelphia, effectively dismissing
Grant's lawsuit without a trial.
James C. Kozlowski, J.D., Ph.D., is an Attorney and Professor
emeritus in the School of Sport, Recreation and Tourism
Management at George Mason University (jkozlows@gmu.
edu). Webpage link to an archive of articles (1982 to present):
mason.gmu.edu/~jkozlows/lawarts/artlist.htm.
Creating
Equity-Based System
Master Plans
NRPA's online tool can help you
create master plans grounded in
equity and inclusion.
nrpa.org/ParkMasterPlanning
PARK S ANDRECRE AT ION . OR G | APRIL 2 0 2 3
| Parks & Recreation
33

https://mason.gmu.edu/~jkozlows/lawarts/artlist.htm http://www.nrpa.org/ParkMasterPlanning

April 2023 - Parks & Recreation

Table of Contents for the Digital Edition of April 2023 - Parks & Recreation

April 2023 - Parks & Recreation - Intro
April 2023 - Parks & Recreation - Cover1
April 2023 - Parks & Recreation - Cover2
April 2023 - Parks & Recreation - 1
April 2023 - Parks & Recreation - 2
April 2023 - Parks & Recreation - 3
April 2023 - Parks & Recreation - 4
April 2023 - Parks & Recreation - 5
April 2023 - Parks & Recreation - 6
April 2023 - Parks & Recreation - 7
April 2023 - Parks & Recreation - 8
April 2023 - Parks & Recreation - 9
April 2023 - Parks & Recreation - 10
April 2023 - Parks & Recreation - 11
April 2023 - Parks & Recreation - 12
April 2023 - Parks & Recreation - 13
April 2023 - Parks & Recreation - 14
April 2023 - Parks & Recreation - 15
April 2023 - Parks & Recreation - 16
April 2023 - Parks & Recreation - 17
April 2023 - Parks & Recreation - 18
April 2023 - Parks & Recreation - 19
April 2023 - Parks & Recreation - 20
April 2023 - Parks & Recreation - 21
April 2023 - Parks & Recreation - 22
April 2023 - Parks & Recreation - 23
April 2023 - Parks & Recreation - 24
April 2023 - Parks & Recreation - 25
April 2023 - Parks & Recreation - 26
April 2023 - Parks & Recreation - 27
April 2023 - Parks & Recreation - 28
April 2023 - Parks & Recreation - 29
April 2023 - Parks & Recreation - 30
April 2023 - Parks & Recreation - 31
April 2023 - Parks & Recreation - 32
April 2023 - Parks & Recreation - 33
April 2023 - Parks & Recreation - 34
April 2023 - Parks & Recreation - 35
April 2023 - Parks & Recreation - 36
April 2023 - Parks & Recreation - 37
April 2023 - Parks & Recreation - 38
April 2023 - Parks & Recreation - 39
April 2023 - Parks & Recreation - 40
April 2023 - Parks & Recreation - 41
April 2023 - Parks & Recreation - 42
April 2023 - Parks & Recreation - 43
April 2023 - Parks & Recreation - 44
April 2023 - Parks & Recreation - 45
April 2023 - Parks & Recreation - 46
April 2023 - Parks & Recreation - 47
April 2023 - Parks & Recreation - 48
April 2023 - Parks & Recreation - 49
April 2023 - Parks & Recreation - 50
April 2023 - Parks & Recreation - 51
April 2023 - Parks & Recreation - 52
April 2023 - Parks & Recreation - 53
April 2023 - Parks & Recreation - 54
April 2023 - Parks & Recreation - 55
April 2023 - Parks & Recreation - 56
April 2023 - Parks & Recreation - Cover3
April 2023 - Parks & Recreation - Cover4
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https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2023
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https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2021
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