913 F.3d 757
8th Cir.2019Background
- Ten plaintiffs (lead plaintiff Keilee Fant) filed a putative class action under 42 U.S.C. § 1983 against the City of Ferguson alleging constitutional violations tied to detention for unpaid traffic fines.
- The City moved to dismiss six of seven counts, asserting sovereign immunity because the harms were allegedly attributable to the Ferguson Municipal Court, which it claimed is an arm of the State of Missouri.
- The district court denied the City’s motion to dismiss, finding the City not entitled to sovereign immunity and that the amended complaint plausibly attributes plaintiffs’ injuries to the City.
- The City sought interlocutory appellate review, invoking the collateral-order doctrine that typically permits immediate appeals of denials of sovereign immunity.
- The City disclaimed any sovereign immunity of its own on appeal and instead sought to invoke the claimed immunity of the nonparty Ferguson Municipal Court.
- The court concluded it lacked jurisdiction to review a denial of immunity that the appellee disavows for itself and that belongs to a nonparty municipal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of sovereign-immunity-based dismissal is immediately appealable | Plaintiffs argued litigation should proceed in district court; immunity not a bar | City argued collateral-order appeal is proper because the municipal court (an arm of the State) is the real party in interest and immune | Appeal dismissed for lack of jurisdiction because City disclaimed its own immunity and invoked immunity of a nonparty |
| Whether the City is entitled to sovereign immunity for the alleged detentions | Plaintiffs alleged injuries are attributable to the City, not state entity | City contended the Ferguson Municipal Court (an arm of the State) caused the injuries, so sovereign immunity applies | District court decision denying immunity stands for now; appellate court did not reach the merits |
| Whether the collateral-order doctrine extends to a party asserting a nonparty’s immunity | Plaintiffs said doctrine does not apply because alleged sovereign is not a party | City urged collateral-order doctrine applies to protect government entities from suit burdens | Court held doctrine does not apply where the claimed sovereign is not a party and appellant disclaims its own immunity |
| Precedential reliance on Webb v. City of Maplewood | Plaintiffs distinguished Webb because appellant here disclaimed its own immunity | City relied on Webb where this Court reviewed a similar claim involving a municipal court | Court explained Webb involved a city asserting its own immunity; here City did not assert its own immunity, so Webb is inapplicable |
Key Cases Cited
- P.R. Aqueduct & Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139 (U.S. 1993) (denial of sovereign immunity can be appealed under the collateral-order doctrine in appropriate circumstances)
- Webb v. City of Maplewood, 889 F.3d 483 (8th Cir. 2018) (city asserted its own sovereign immunity from suit involving a municipal court)