David Snyder v. J. King etal
2014 U.S. App. LEXIS 4528
7th Cir.2014Background
- David Snyder, a Roseland town council member, was convicted of misdemeanor battery in 2008, served jail time, and was released in May 2009.
- While incarcerated, county voter-registration officials removed Snyder from the voter rolls under Indiana statutes disenfranchising persons imprisoned following conviction.
- Snyder sued under 42 U.S.C. § 1983 against state election directors (State Defendants) and county voter-registration board members (County Defendants) alleging violations of federal voting statutes, the First and Fourteenth Amendments, and the Indiana Constitution.
- The district court dismissed the State Defendants on sovereign-immunity grounds and dismissed the County Defendants for failure to state a Monell claim (county merely implemented statutory removal); it also addressed but needlessly reached mootness/injunctive-relief arguments.
- The Seventh Circuit affirmed: Snyder waived challenge to dismissal of State Defendants, and he failed to plead a municipal policy or custom causing the alleged deprivation, so no § 1983 claim against the County; prospective relief and nominal damages therefore unavailable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether State Defendants were proper parties despite sovereign immunity | Snyder sought relief against state election directors for disenfranchisement | State officials are immune from suit in their official capacities | Dismissal affirmed; Snyder waived challenge to dismissal |
| Whether County Defendants can be liable under § 1983 (Monell) | County had discretion to interpret statute and chose to remove misdemeanants, so county policy caused deprivation | County implemented mandatory state statutory scheme and had no policymaking discretion on removals | Dismissed for failure to plead municipal policy; Monell requirements not met |
| Whether nominal damages remain available against County Defendants | Nominal damages would preserve a live controversy for constitutional violation | No § 1983 claim exists against county; cannot recover damages without stating a claim | Nominal damages unavailable because no viable § 1983 claim pleaded |
| Whether injunctive/declaratory relief against County Defendants survives | Snyder sought reinstatement and declaratory relief; claimed controversy remains | Monell policy-or-custom requirement applies to equitable relief too; no claim pleaded | Equitable relief unavailable against County for same Monell deficiency |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipalities liable under § 1983 only for official policies or customs)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (state officials in official capacity are not "persons" under § 1983)
- Bethesda Lutheran Homes and Servs., Inc. v. Leean, 154 F.3d 716 (7th Cir.) (county cannot be held liable for acts done under command of state law)
- Los Angeles Cnty. v. Humphries, 131 S.Ct. 447 (policy-or-custom requirement applies to prospective equitable relief under § 1983)
- Calhoun v. DeTella, 319 F.3d 936 (7th Cir.) (successful constitutional plaintiffs entitled to nominal damages)
- Pembaur v. Cincinnati, 475 U.S. 469 (final policymaker standard for municipal liability)
- Mercado v. Dart, 604 F.3d 360 (7th Cir.) (distinguishing mandatory state directives that still leave room for local policy on implementation)