Campbell v. City of Spencer
2014 U.S. App. LEXIS 23700
| 10th Cir. | 2014Background
- Ann Campbell kept horses on parcels in Spencer and Forest Park, Oklahoma; officers observed multiple emaciated horses and obtained a search warrant for one parcel, then—accompanied by Blaze employees—seized 44 horses from three parcels.
- Spencer and Forest Park filed a civil forfeiture petition under Okla. Stat. tit. 21 § 1680.4; the state district court found probable cause and ordered forfeiture; the Oklahoma Court of Civil Appeals affirmed and the Oklahoma Supreme Court denied certiorari.
- Campbell did not raise Fourth Amendment challenges (warrant sufficiency or scope) in the forfeiture proceeding.
- Campbell then sued the municipalities and Blaze under 42 U.S.C. § 1983, alleging (1) material omissions in the warrant affidavit and (2) execution beyond the warrant’s scope; she sought compensatory relief equal to the value of the horses.
- The federal district court dismissed the § 1983 claims based on claim and issue preclusion; the Tenth Circuit reviews de novo and affirms, holding claim preclusion bars Campbell’s § 1983 suit because she could have raised the constitutional claims in the forfeiture proceeding and allowing them now would impair rights established by the forfeiture judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claim preclusion bars Campbell’s § 1983 Fourth Amendment claims | Campbell: forfeiture hearing didn’t meaningfully examine warrant legality or omissions; constitutional issues were not and could not be fully litigated there | Municipalities: Oklahoma res judicata bars claims that could have been raised in the forfeiture; success now would nullify or impair the forfeiture judgment | Held: Claim preclusion bars the § 1983 claims because Campbell could have raised suppression/warrant challenges in the forfeiture proceeding and success now would impair rights from that judgment |
| Whether Oklahoma forfeiture proceedings permit exclusion/suppression arguments | Campbell: alleged limitations of the forfeiture hearing meant suppression could not be litigated | Municipalities: state law and precedent allow suppression and Fourth Amendment arguments in civil forfeiture | Held: Oklahoma law and U.S. precedent permit exclusionary-rule and Fourth Amendment challenges in civil forfeiture, so the remedy was available in state court |
| Whether success on § 1983 claims would necessarily nullify the forfeiture judgment | Campbell: a federal judgment would not automatically undo the forfeiture; issues are separable | Municipalities: monetary recovery for the horses’ value would undercut the forfeiture’s effect and rights conveyed | Held: Even if not automatically nullifying, awarding value of the horses would impair and suggest invalidity of the forfeiture, supporting preclusion |
| Whether Rooker–Feldman or issue preclusion independently bar the claims | Campbell: previous Tenth Circuit decision rejected Rooker–Feldman as a bar | Municipalities: alternative preclusion doctrines apply | Held: Rooker–Feldman already rejected earlier; court resolves the case on claim preclusion and does not need to decide issue preclusion or merits of § 1983 claim |
Key Cases Cited
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (federal courts must give state judgments the preclusive effect they would have in the originating state)
- One 1958 Plymouth Sedan v. Pennsylvania, 380 U.S. 693 (exclusionary rule applies in state civil forfeiture proceedings)
- Pennzoil Co. v. Texaco, 481 U.S. 1 (federal courts may assume state procedures provide adequate remedies for unraised federal claims)
- Taylor v. Meachem, 82 F.3d 1556 (10th Cir.) (knowingly or recklessly omitting material facts from affidavit can violate the Fourth Amendment)
- United States v. Angelos, 433 F.3d 738 (10th Cir.) (warrant must particularly describe the place to be searched and execution may not exceed scope)
- Frazee v. I.R.S., 947 F.2d 448 (10th Cir.) (legality of a seizure may be tested in a judicial forfeiture)
- Cordova v. Aragon, 569 F.3d 1183 (10th Cir.) (municipal § 1983 liability requires constitutional violation and a municipal policy or custom)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts lack appellate jurisdiction over state-court judgments)
- Wilkes v. Wyoming Dept. of Employment Div. of Labor Standards, 314 F.3d 501 (10th Cir.) (standard explaining claim preclusion doctrine)