An excerpt from Judge Benjamin Settle's longish opinion Monday in Bromm v. Lewis County (W.D. Wash.):
Plaintiff Paul Bromm was employed as a part-time Deputy Coroner with Lewis County. After conservative activist and media personality Charlie Kirk was shot in September 2025, Bromm shared memes and made other posts on his Facebook that appeared to make light of the killing, even suggesting it was deserved.
Bromm was placed on administrative leave and then terminated for his posts. Bromm sued Lewis County, the City of Centralia, and five individual defendants, asserting 42 U.S.C. § 1983 claims premised on alleged violations of his First Amendment right to free speech, and that defendant [County] Commissioner Sean Swope "doxed" him in violation of RCW 4.24.792.
The court dismissed Bromm's First Amendment claim against the individual defendants, finding that it was barred by prosecutorial immunity (as to a prosecutor) and qualified immunity (as to the others). The government defendants didn't move for summary judgment. Here's the underlying post, followed by the meat of the qualified immunity analysis:
