Arch Energy, L.C. v. City of Brentwood, 4:22-cv-00499

Arch Energy, L.C. sued the City of Brentwood and several Brentwood officials in Missouri state court, asserting four counts: declaratory judgment, inverse condemnation, §1983 deprivation of civil rights, and conspiracy to deprive constitutional rights.
Defendants removed the case to federal court asserting federal-question jurisdiction under 28 U.S.C. § 1331 because Counts III and IV invoke 42 U.S.C. § 1983 and constitutional provisions.
The Amended Petition bundles multiple constitutional theories (Fifth Amendment takings, due process, Fourteenth Amendment equal protection) together within single §1983 counts and incorporates all preceding paragraphs into the conspiracy count.
The complaint’s muddled pleading made it impossible for the Court to identify which precise constitutional right is alleged in each §1983 count or which defendants are alleged conspirators.
The Court concluded the pleading amounted to impermissibly vague/shotgun pleading, denied the pending Motion to Dismiss without prejudice as moot, and ordered Arch Energy to file an amended complaint within 21 days (with defendants to answer thereafter).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal-question jurisdiction over removed action	Arch’s §1983 Counts invoke federal rights, so federal jurisdiction exists	Removal appropriate because federal claims are pleaded	Held: Federal-question jurisdiction exists because Counts III and IV are §1983 claims created by federal law
Sufficiency/clarity of §1983 pleading — identification of precise constitutional right	Arch alleges due process, takings, equal protection across counts (seeks to preserve all theories)	Defendants argue claims are not properly pleaded and unfairly shift burden to defendants and court	Held: Complaint fails to isolate the specific constitutional right(s) for each §1983 claim; court cannot properly rule on motion to dismiss and orders repleading
Conspiracy claim specificity and defendant identification	Arch alleges a conspiracy to deprive constitutional/property rights, incorporating all prior allegations	Defendants contend incorporation and vague group pleading obscure who conspired and what conduct is wrongful	Held: Count IV is unclear (who conspired, what rights violated); incorporation compounds defect; plaintiff must clarify in amended complaint

Great Lakes Gas Transmission Ltd. P’ship v. Essar Steel Minnesota LLC, 843 F.3d 325 (8th Cir. 2016) (federal-question jurisdiction doctrine for well-pleaded complaints)
Williams v. Ragnone, 147 F.3d 700 (8th Cir. 1998) (federal-question jurisdiction standards)
Albright v. Oliver, 510 U.S. 266 (1994) (§1983 is procedural; must identify specific constitutional right alleged)
Baker v. McCollan, 443 U.S. 137 (1979) (§1983 vindicates federal rights elsewhere conferred)
Graham v. Connor, 490 U.S. 386 (1989) (first inquiry in §1983 is to isolate precise constitutional violation)
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (identify exact contours of the underlying right in §1983 actions)
Weiland v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313 (11th Cir. 2015) (criticizing complaints that incorporate all preceding allegations as shotgun pleading)
Superior Edge, Inc. v. Monsanto Co., 44 F. Supp. 3d 890 (D. Minn. 2014) (discussing incorporation by reference and notice sufficiency)
Gurman v. Metro Housing & Redevelopment Auth., 842 F. Supp. 2d 1151 (D. Minn. 2011) (courts should not be forced to identify plaintiff’s viable claims for them)