On December 3, 2025, Atlanta Partners Carrie Christie, Courtney Norton, and Savannah Wharton won a motion to dismiss in the United States District Court for the Middle District of Georgia in a case in which the plaintiff asserted claims under 42 U.S.C. § 1983 for conspiracy and defamation, and alleged a violation of parental rights under the Family Educational Right and Privacy Act (FERPA) against various government and private entities and individuals. The court agreed with Carrie Christie and her defense team that the plaintiff’s Section 1983 and FERPA claims failed for want of any plausible allegation that the defendant acted under color of state law and the conspiracy and defamation claims failed because the defendant’s statements were contained within an official court document and, thus, they were afforded absolute privilege under Georgia law and Eleventh Circuit common law immunity.
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