Crawford v. VAN BUREN COUNTY, ARK., 678 F.3d 666

Since 1995 Crawford operated a kennel from her Arkansas home.
In 2005, Fogle seized ~163 dogs from Crawford's property under a search warrant; Crawford pled guilty to animal cruelty; property forfeited to the county; periodic access rights granted to Fogle for a year.
In 2006, a second warrant led to seizure of 201 dogs and related supplies; Crawford was found guilty in a bench trial and property forfeited; sentence included jail time and conditions.
On appeal, Crawford successfully moved to suppress in state court; later nolle prosequi was entered after the 2009 disappearance of the key official.
In this §1983 action, Crawford claimed Fifth/Fourth Amendment violations, due process, conspiracy, and state-law torts arising from the seizures.
The district court granted summary judgment to all defendants; Crawford appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
County liability for a custom or policy	Fogle's actions reflect county policy or widespread custom.	No evidence of a county policy or pervasive custom; actions not a policy violation.	No genuine policy/custom liability; summary judgment for county affirmed.
Exhaustion of state remedies under Rule 15.2	State remedies were available and not exhausted.	Crawford failed to exhaust under Rule 15.2.	Exhaustion not completed; remedies inadequate; claims barred.
Heck v. Humphrey bar on 2005 claims	Conspiracy/possession claims independent of conviction.	A favorable ruling would imply invalidity of conviction.	2005 claims barred by Heck.
Conspiracy against private Humane Society defendants	Humane Society defendants conspired with state actors for seizures.	No probative evidence of civil conspiracy beyond mere presence at search.	No evidence of conspiracy; summary judgment for Humane Society defendants affirmed.

Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (federal claims barred if would imply invalidity of conviction)
Veatch v. Bartels Lutheran Home, 627 F.3d 1254 (8th Cir. 2010) (policy/custom liability requires widespread pattern, not single act)
Rynders v. Williams, 650 F.3d 1188 (8th Cir. 2011) (liability for official custom or usage requires continuing pattern)
City of St. Louis v. Praprotnik, 485 U.S. 112 (U.S. 1988) (policy must be set by final policymakers)
Jenkins v. Cnty. of Hennepin, 557 F.3d 628 (8th Cir. 2009) (reiterates requirement of persistent unconstitutional conduct for custom)
Marksmeier v. Davie, 622 F.3d 896 (8th Cir. 2010) (concerning evidence required to prove official misconduct)
Dossett v. First State Bank, 399 F.3d 940 (8th Cir. 2005) (civil conspiracy requires more than presence at event)
Barber v. C1 Truck Driver Training, LLC, 656 F.3d 782 (8th Cir. 2011) (summary judgment standard requires substantial evidence, not speculation)
Walden v. Carmack, 156 F.3d 861 (8th Cir. 1998) (adequate state post-deprivation remedies defeat due process claims)
Alexander/Ryahim v. Monroe, 326 Fed.Appx. 977 (8th Cir. 2009) (unpublished per curiam; exhaustion analysis guidance)
Carniglia v. Dearmon, 16 Fed.Appx. 548 (8th Cir. 2001) (unpublished per curiam; post-deprivation remedies adequate)