Individuals for Responsible Government, Inc. v. Washoe County

How later courts describe this case

• holding that a recycling service charge was analogous to a property tax and therefore not subject to challenge as a taking of property
• explaining that decisions from only these courts clearly establish the law for the purposes of qualified immunity
• no actionable claim for unconstitutional municipal policy or failure to train where there has been no constitutional violation
• “A complaint can be long-winded, even prolix, without pleading with particularity. Indeed, such a garrulous style is not an uncommon mask for an absence of detail.”
• Only the U.S. Supreme Court, the Eleventh Circuit, and "the highest court of the state where the case arose” may clearly establish rights under federal law relevant to qualified immunity analysis
• “A complaint can be long-winded, even prolix, without pleading with particularity. Indeed, such a garrulous style is not an uncommon mask for an absence of detail The amended complaint here, although long, states little with particularity.”
• individual defendants entitled to qualified immunity