of the Black Lives Matter movement along with smart phone video cameras have made Section 1983 lawsuits easier to obtain because of technological advances, including bodycams worn by law enforcement. The Act was invoked in the 2010 Robbins v. Lower Merion School District case, where plaintiffs charged two suburban Philadelphia high schools secretly spied on students by surreptitiously and remotely activating webcams embedded in school-issued laptops the students were using at home, violating their right to privacy. The schools admitted to snapping over 66,000 webshots and screenshots secretly, including webcam shots of students in their bedrooms. The 2019 Supreme Court case Nieves v. Bartlett ruled that in general when probable cause for an arrest exists it overrides a First Amendment retaliatory arrest claim arising under section 1983, but that there are some narrow exceptions to this. Because officers can exercise their discretion in making arrests for warrantless misdemeanor crimes, a plaintiff can succeed on a section 1983 claim if they can present objective evidence that other similarly situated individuals who were not engaged in protected speech had not been arrested. Also in 2019, the Court held that the 3-year statute of limitations for a fabrication of evidence civil lawsuit under section 1983 of the Civil Rights Act begins to run when the criminal case ends in the plaintiff's favor. In June 2020 the United States Court of Appeals for the Fourth Circuit rejected qualified immunity for five Police officers in West Virginia who had kicked, beaten, tased, and finally killed Wayne A. Jones, by shooting him 22 times. On February 16, 2021, the Act was asserted in an action in the District Court, D.C., by Rep. Bennie G. Thompson (D, MS2), chair of the House Homeland Security Committee (in his personal capacity) against former President Donald Trump (in his personal capacity), Trump's attorney Rudolph Giuliani and (far-right "militia" groups) Proud Boys and Oath Keepers. The Thompson v. Trump., et al. case was followed by a subsequent action filed August 26, 2021, by seven Capitol Police officers, reportedly against the same defendants. See also Antebellum South Carolina Kirk–Holden War, an 1870 struggle against the Klan in North Carolina References Works cited (PDF) (PDF) (PDF) (PDF) (PDF) External links Full text of the Enforcement of 1871 (simplified version) Text of Enforcement Act of 1871 as codified- 42 U.S. Code 21 §§1983, 1988 18 U.S.C. § 242 is "the criminal analog of 1983."