Cecelia Webb v. City of Maplewood
889 F.3d 483
| 8th Cir. | 2018Background
- Plaintiffs (Cecelia Webb and five others) filed a putative class action under 42 U.S.C. § 1983 against the City of Maplewood, alleging a municipal policy or custom of issuing arrest warrants when motorists fail to pay fines or appear in municipal court.
- Plaintiffs allege arrest leads to a pre-set bond demand (no inquiry into ability to pay), or extended detention, effectively coercing payment and producing recurrent arrest/jail cycles that target indigent motorists.
- Plaintiffs claim these practices violate due process and equal protection and seek to hold the City liable under Monell for its policy or custom.
- The City moved to dismiss, arguing (1) Eleventh Amendment sovereign immunity because the municipal court (an arm of the State) is the real party in interest, and (2) municipal immunity because the identified officials enjoy personal (absolute) immunity.
- The district court denied the City’s immunity defense and allowed municipal-liability claims to proceed (except one count dismissed by consent); the City appealed the denial of immunity.
- The Eighth Circuit affirmed the district court, rejecting both Eleventh Amendment and absolute-official-immunity shields to dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the City is protected by Eleventh Amendment sovereign immunity because the municipal court (an arm of Missouri) is the real party in interest | City is responsible for practices; plaintiffs sue City for constitutional violations | The municipal court is an arm of the State and the real party in interest, so sovereign immunity bars suit against the City | Rejected — municipalities do not enjoy Eleventh Amendment immunity; even if the court is responsible, that is a merits defense, not immunity from suit |
| Whether absolute immunity of municipal officials prevents municipal liability | Plaintiffs contend City can be liable under Monell despite some officials’ immunity | If all responsible officials are personally immune, no unlawful acts exist to support municipal liability, so City is immune | Rejected — official immunity does not automatically preclude a Monell claim against the municipality |
| Whether appellate court may review interlocutory denial of failure-to-state municipal-liability claim | Plaintiffs seek to proceed on municipal-liability pleadings | City asks appellate review of sufficiency of Monell allegations along with immunity denial | Denied — interlocutory review of the complaint’s sufficiency is not available here because that issue is not coterminous with the immunity question; court limited to immunity ruling |
| Whether concerns about subpoenas to State actors justify granting immunity now | Plaintiffs might seek discovery from State officials | City argues immunity should prevent discovery burdens on State | Court notes State actors can assert sovereign immunity at discovery and district court may rule on quash motions; not a basis for municipal immunity now |
Key Cases Cited
- Leatherman v. Tarrant Cty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163 (municipalities are suable under § 1983)
- Jinks v. Richland Cty., 538 U.S. 456 (distinguishing state immunity from municipal non-immunity)
- Lake Country Estates, Inc. v. Tahoe Reg'l Planning Agency, 440 U.S. 391 (political subdivisions are not entitled to Eleventh Amendment immunity)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (municipal liability can attach even if individual policymakers may be immune for certain functions)
- Owen v. City of Independence, 445 U.S. 622 (availability of municipal liability as a remedy when officials are immune)
- Bogan v. Scott-Harris, 523 U.S. 44 (legislative immunity for officials does not bar municipal liability under Monell)
- Sample v. City of Woodbury, 836 F.3d 913 (standard of review for immunity determinations)
- McDonough v. Anoka Cty., 799 F.3d 931 (absolute immunity of policymakers does not shield municipality from Monell liability)