Maleeha Ahmad v. City of St. Louis, Missouri, 995 F.3d 635

Background

In Sept. 2017 St. Louis protests following a police acquittal, police deployed crowd-control tactics (macing/tear gas), made mass arrests, seized/inspected phones, and some officers acted abusively (including assault of an undercover detective).
Plaintiffs (a protester allegedly maced, a person whose phone was seized while filming, and an observer allegedly exposed to chemical agents and arrested) sued under § 1983 for First, Fourth, and Fourteenth Amendment violations and sought injunctive relief restricting how the City handles protests.
The district court held a three-day evidentiary hearing and entered a substantive preliminary injunction (Nov. 2017) limiting when officers may declare unlawful assemblies, use chemical agents, and issue dispersal orders; the City did not timely appeal that injunction.
The case lingered in mediation and additional proceedings for years; the district court later certified a Rule 23(b)(2) class (May 2019) and denied the City’s motion to dissolve the preliminary injunction; the City timely appealed those orders.
The Eighth Circuit (majority) affirmed denial of the motion to dissolve but concluded the preliminary injunction (a mandatory-style decree) could not remain open-ended: it conditioned maintenance of the injunction on completing a trial on the merits within six months and ordered the injunction dissolved by Oct. 31, 2021 if no final merits ruling issued; it vacated class certification without prejudice as premature.

Issues

Issue	Plaintiffs' Argument	City’s Argument	Held
Whether the district court abused its discretion in denying the City’s motion to dissolve the preliminary injunction (Rule 60(b)/changed circumstances).	Injunction was necessary to prevent ongoing constitutional violations and preserve parties’ positions pending trial.	Changed circumstances (passage of time, new counsel, mediation delays) and Rule 60(b) relief justify dissolution/modification.	Majority affirmed denial but found passage of time and prolonged delay warranted requiring a prompt trial; injunction must be replaced by a final merits order within six months or be dissolved by Oct. 31, 2021.
Whether a Rule 23(b)(2) class may be certified for the sought prospective relief.	Classwide injunctive relief is appropriate because City policies/practices affected protestors and observers generally.	Claims are individualized (different facts, remedies); (b)(2) requires cohesiveness and uniform relief.	Vacated class certification without prejudice as premature—claims require individualized inquiries and (b)(2) cohesion lacking.
Standard for permanent municipal injunctive relief based on custom/practice or failure to train.	Plaintiffs rely on Sept. 2017 incidents to show municipal custom/practice and inadequate training/supervision.	Isolated incidents and officer misconduct do not establish municipal policy, deliberate indifference, or a pattern justifying broad equitable relief.	Court emphasized rigorous § 1983 standards: a few incidents are insufficient; more proof of widespread/persistent misconduct or deliberate indifference is required for permanent injunctive relief.
Whether mere passage of time (delay) alone suffices as a changed circumstance to modify/dissolve a preliminary injunction (dissenting view).	Delay and prolonged federal control over local policing justify reconsideration/modification.	Passage of time alone is insufficient; City failed to identify new facts or law; lack of timely appeal limits review (dissent).	Majority treated extended delay as a significant changed circumstance warranting conditioning the injunction on an expedited merits trial; a concurrence/dissent argued the appeal should be dismissed for lack of jurisdiction.

Key Cases Cited

Horne v. Flores, 557 U.S. 443 (Rule 60(b)(5) permits modification where significant change in facts or law renders continued enforcement inequitable)
Rufo v. Inmates of Suffolk Cty. Jail, 502 U.S. 367 (standards for modifying institutional reform decrees)
Lyons v. City of Los Angeles, 461 U.S. 95 (limits on equitable relief absent showing of likelihood of future harm)
Bd. of Cty. Comm’rs v. Brown, 520 U.S. 397 (municipal liability requires rigorous causation/culpability showing)
City of Canton v. Harris, 489 U.S. 378 (standards for failure-to-train municipal liability)
Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (Rule 23(b)(2) requires that a single injunction provide relief to each class member)
Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109 (purpose of preliminary injunction is to preserve positions pending a merits decision)
Able v. United States, 44 F.3d 128 (conditioning maintenance of injunction on expedited trial where discovery largely complete)
Chicago United Inds., Ltd. v. City of Chicago, 445 F.3d 940 (rebuttable presumption that governmental misconduct will not recur; caution against federal micromanagement)
Lewis v. Casey, 518 U.S. 343 (equitable relief must be limited to the inadequacy that produced the injury)