Jason Stockley v. Jennifer Joyce
963 F.3d 809
8th Cir.2020Background
- In 2011 SLMPD officers Jason Stockley and Brian Bianchi chased and then Stockley fatally shot Anthony Smith; Stockley was later acquitted at bench trial.
- SLMPD Internal Affairs (FIU) initially investigated; in 2016 Circuit Attorney Jennifer Joyce reopened/terminated FIU investigation and filed first-degree murder charges; SLMPD sergeant Kirk Deeken signed a probable-cause affidavit.
- A state judge found probable cause and a grand jury indicted; Stockley was arrested and tried but acquitted when the court found the government had not proved guilt beyond a reasonable doubt.
- Stockley sued under 42 U.S.C. § 1983 (due process and Monell claims) and state torts (defamation against Joyce; malicious prosecution against Deeken). District court dismissed all claims; Stockley appealed.
- The Eighth Circuit reviewed Rule 12(b)(6) dismissal de novo and affirmed the dismissal in a published opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Joyce is entitled to absolute prosecutorial immunity for terminating FIU investigation and charging Stockley | Joyce’s termination of FIU and late 2016 charging were investigative misconduct not protected by absolute immunity | Initiation of prosecution and charging decisions are core prosecutorial functions entitled to absolute immunity | Joyce is absolutely immune for the charging/termination decision; dismissal affirmed |
| Whether Joyce’s public statements claiming she had "new evidence" (and that it proved guilt) violated substantive due process or constituted defamation | Statements were false, prejudicial, conscience-shocking and harmed reputation | Media comments are not immune but did not shock the conscience and any reputational harm flowed from the arrest/prosecution (for which she is immune) | Statements did not satisfy conscience-shocking standard; defamation claim failed for lack of pleaded distinct reputational harm from charges |
| Whether Deeken’s probable-cause affidavit (alleged misstatements/omissions) violated substantive due process | Affidavit included false material facts and omitted exculpatory facts, reflecting reckless/intentional failure to investigate | Alleged misstatements/omissions would not make it impossible to find probable cause; due-process claim is foreclosed by Fourth Amendment principles | Due-process claim dismissed: Manuel makes pretrial-probable-cause complaints Fourth-Amendment claims; omissions/misstatements insufficient to show conscience-shocking conduct |
| Whether Deeken maliciously prosecuted Stockley under Missouri law | Affidavit instigated prosecution without probable cause and with malice | State judge’s probable-cause finding creates presumption of probable cause; plaintiff’s allegations do not rebut it or show legal malice | Malicious-prosecution claim fails: probable-cause presumption unrebutted and malice not adequately pleaded |
| Whether the City can be liable under Monell for Joyce’s charging decision or her public statements | Joyce acted as final policymaker; her conduct was municipal policy/custom causing constitutional harm | No underlying constitutional violation by individuals (or immunity) and single charging decision was not a municipal policy/prescribed practice | Monell claim dismissed: no individual constitutional violation; Joyce’s charging decision was an individual act, not municipal policy |
Key Cases Cited
- Imbler v. Pachtman, 424 U.S. 409 (prosecutorial immunity for initiating prosecution and presenting the state’s case)
- Buckley v. Fitzsimmons, 509 U.S. 259 (prosecutor’s investigatory acts not entitled to absolute immunity)
- Manuel v. City of Joliet, 137 S. Ct. 911 (claims that pretrial detention lacked probable cause are governed by the Fourth Amendment)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability under § 1983 for official policy or custom)
- Brodnicki v. City of Omaha, 75 F.3d 1261 (charging decisions are core prosecutorial functions entitled to immunity)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (single decision by final policymaker can be municipal policy in some circumstances)
- Franks v. Delaware, 438 U.S. 154 (standard for attacking a warrant affidavit based on false statements)