Crump v. Boester
4:14-cv-01975
E.D. Mo.Apr 25, 2016Background
- Plaintiff Mario Crump alleges SLMPD Officers Boester and Schaffer used excessive force on March 21, 2014, then made false statements and manufactured charges to conceal misconduct. Other officers allegedly failed to report the incident.
- Crump sued for multiple federal and state claims; Count VIII asserts municipal/supervisory liability for failure to instruct, supervise, control, and discipline and names Chief Samuel Dotson and the St. Louis Board of Police Commissioners (Board Defendants).
- Count VIII alleges widespread SLMPD customs: use of excessive force, fabrication of charges to justify force, concealment of misconduct, inadequate investigations, biased media statements, and mistreatment of mentally ill citizens.
- Defendants moved to dismiss Count VIII under Rule 12(b)(6), arguing Crump pleads only conclusory allegations and fails to show a policy, custom, or deliberate indifference sufficient for § 1983 liability; Dotson asserts qualified immunity and lack of personal participation or notice of a pattern.
- The court applied the Twombly/Iqbal pleading standards and Monell/City of Canton framework and concluded Crump’s allegations are conclusory and insufficient to plausibly plead an official policy, municipal custom, or deliberate indifference in training/supervision, and Dotson lacks personal involvement or notice of a pattern.
- The court granted both motions to dismiss as to Dotson and the Board Defendants (Count VIII).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of an unconstitutional official policy (Monell) | Crump contends SLMPD policies or decisions by final policymakers caused his injury | Defendants say no specific policy is alleged; only conclusory assertions | Dismissed — no factual allegations supporting an official policy |
| Municipal custom / pattern of misconduct | Crump alleges widespread, persistent customs causing constitutional violations | Defendants argue single-incident facts can’t show a continuing, widespread pattern; allegations are conclusory | Dismissed — insufficient factual allegations of a widespread pattern or notice |
| Failure to train / supervise (deliberate indifference) | Crump alleges Board and Dotson were responsible for training/supervision and were aware of deficiencies | Defendants say no facts show training was inadequate, no pattern, and no notice to policymakers | Dismissed — no plausible allegation of deliberate indifference or causation |
| Supervisory liability / Dotson’s individual liability & qualified immunity | Crump alleges Dotson received notice and failed to investigate or discipline, ratifying misconduct | Dotson contends no direct participation or actual notice of a pattern; qualified immunity applies | Dismissed — Dotson not alleged to have direct involvement or requisite notice; qualified immunity defense sustained |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; conclusory allegations insufficient)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Monell v. Department of Social Services, 436 U.S. 658 (municipal liability under § 1983)
- City of Canton v. Harris, 489 U.S. 378 (failure-to-train standard; deliberate indifference)
- Connick v. Thompson, 563 U.S. 51 (pattern ordinarily necessary to show deliberate indifference)
- Crumpley‑Patterson v. Trinity Lutheran Hosp., 388 F.3d 588 (pleading must allege facts to support unconstitutional policy)
- Ulrich v. Pope County, 715 F.3d 1054 (isolated incident cannot establish municipal custom)
- Jenkins v. County of Hennepin, 557 F.3d 628 (municipal custom and tacit authorization/deliberate indifference)
- Mettler v. Whitledge, 165 F.3d 1197 (policy vs. custom distinction)
- Rodgers v. Knight, 781 F.3d 932 (failure-to-train elements)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Parrish v. Ball, 594 F.3d 993 (need for personal involvement in § 1983 suits)
- Livers v. Schenck, 700 F.3d 340 (supervisory liability / notice pattern elements)
- Andrews v. Fowler, 98 F.3d 1069 (notice that training/supervision inadequate)
- Otey v. Marshall, 121 F.3d 1150 (supervisor liable if failure to train/supervise caused deprivation)
- Liebe v. Norton, 157 F.3d 574 (failure to supervise governed by deliberate indifference)
- Board of Commissioners of Bryan County v. Brown, 520 U.S. 397 (liability for failure to train may require pattern)
- Hager v. Arkansas Department of Health, 735 F.3d 1009 (qualified immunity and pleading review)