Coates v. Powell
2011 U.S. App. LEXIS 7147
| 8th Cir. | 2011Background
- Coates sued Missouri State Highway Patrolman Powell, Officer Glandon, and others under §1983 and state tort claims arising from a child neglect investigation at her home.
- Powell and several defendants settled with Coates on the eve of trial; the district court denied attorney's fees for those settlements as prevailing-party status.
- Glandon was granted summary judgment on qualified immunity regarding Coates's §1983 claim for remaining in her home after consent was revoked.
- The events included an entry without a warrant, consent from Coates's boyfriend, a brief stay of 10–15 minutes, and removal of Coates after the investigation proceeded.
- Powell later arrested Coates for citation-related issues, applying a CLAMP maneuver that allegedly broke her arm during handcuffing.
- Coates appealed, challenging both the denial of §1988 fees and the qualified-immunity ruling for Glandon.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Coatesprevailing-party status entitles §1988 fees | Coates argues the private settlement granted prevailing-party status under Buckhannon and related linchpins. | Glandon/Defendants contend no judicial imprimatur; settlement lacked court-approved alteration of legal relationship. | No prevailing-party status; fees denied |
| Whether Glandon validly entitled to qualified immunity for staying in Coates's home | Coates contends continued presence violated clearly established Fourth Amendment rights without exigent circumstances. | Glandon argues Missouri statute authorized assistance and reasonable reliance on that duty. | Glandon entitled to qualified immunity |
Key Cases Cited
- Buckhannon Bd. & Care Home, Inc. v. West Virginia Dep't of Health and Human Resources, 532 U.S. 598 (U.S. 2001) (private settlement lacks judicial imprimatur to confer prevailing-party status)
- Bill M. v. Nebraska Dep't of Health and Human Services, 570 F.3d 1001 (8th Cir. 2009) (oral settlement not reduced to writing and not judicially sanctioned fails to create prevailing-party status)
- Christina A v. Bloomberg, 315 F.3d 990 (8th Cir. 2003) (private settlement lacking judicial imprimatur does not yield prevailing-party status)
- Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-step qualified-immunity framework (subject to Pearson modification))
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (clarifies that the two-step sequence in Saucier is not mandatory)
- Omni Behavioral Health v. Miller, 285 F.3d 646 (8th Cir. 2002) (standard for assessing qualified immunity on summary judgment)
- Kloch v. Kohl, 545 F.3d 603 (8th Cir. 2008) (general-duty statute can support reasonableness; per se rule not absolute)
- Roska ex rel. Roska v. Peterson, 328 F.3d 1230 (10th Cir. 2003) (statutory authority as a factor in objective reasonableness)
- Georgia v. Randolph, 547 U.S. 103 (U.S. 2006) (whether consent is valid when a third party is present; separate from domestic-violence contexts)
- Payton v. New York, 445 U.S. 573 (U.S. 1980) (home-entry with no warrant generally prohibited absent exigent circumstances)
- United States v. McMullin, 576 F.3d 810 (8th Cir. 2009) (relevance to home-entry and consent scenarios under Fourth Amendment)