Elizabeth Fuller v. Karl R. Hade, Johnathan E. Green, E. Elizabeth Edwards, Supreme Court of Virginia

INTRODUCTION
1. On or about October 4, 2021, Plaintiff, a former magistrate for the City of
Alexandria, made public comments to the Alexandria Times concerning official misconduct and
the system’s failure to protect a rape victim that ultimately led to her murder. In retaliation, her
employment was terminated nearly two weeks after Plaintiff’s public comments, effective
October 19, 2021.
2. Plaintiff brings this action against all Defendants in their personal capacities for
damages under Section 1983 of Title 42 of the U.S. Code and the First Amendment to the U.S.
Constitution for employment retaliation.
3. Plaintiff also challenges the constitutionality of Canon 3, Section B(6) of the
Canons of Conduct for Virginia Magistrates as overly broad and vague as applied to Plaintiff.
On this ground, Plaintiff sues all Defendants in their official capacities in carrying out
administrative functions to enjoin them from applying this overly broad and vague canon to
terminate Plaintiff’s employment for her comments to the Alexandria Times.
4. Plaintiff sues Defendants for their administrative actions taken against Plaintiff’s
employment, which are not judicial acts.