Mark Robbins v. Randy Becker, Sr.
2013 U.S. App. LEXIS 10278
| 8th Cir. | 2013Background
- Robbins allege the district court denied summary judgment on the Missouri State Highway Patrol officers’ qualified immunity defenses to §1983 and Sherman Act claims.
- Robbins contend the district court did not apply the two-step qualified immunity framework to all claims and failed to discuss material facts.
- The district court’s order was sparse, lacking explicit application of the qualified immunity analysis or a clear fact-finder posture.
- The district court did not identify which facts the Robbins presented that could overcome the officers’ immunity defense.
- This interlocutory appeal seeks review of the denial of qualified immunity and remand for a detailed, step-by-step analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly applied the two-step qualified immunity analysis. | Robbins argues the district court failed to perform the two-step test. | Officers contend the district court did apply immunity principles at a high level. | Remanded for thorough two-step analysis. |
| Whether the court has jurisdiction to review the legal aspects of the denial on an interlocutory basis. | Robbins asserts the district court’s legal analysis is reviewable. | Officers emphasize appellate review of legal questions only. | Court accepts jurisdiction to review the legal questions; remands for proper analysis. |
| Whether the remand should include explicit findings of fact and legal conclusions. | Robbins seeks explicit factual and legal determinations to permit review. | Officers seek a clear, legally reasoned decision. | Remand required for explicit findings and reasoning. |
Key Cases Cited
- McNeese v. City of Columbia, 675 F.3d 1158 (8th Cir. 2012) (remand when district court's immunity analysis is incomplete)
- Solomon v. Petray, 699 F.3d 1034 (8th Cir. 2012) (remand for explicit consideration of qualified immunity)
- Handt v. Lynch, 681 F.3d 939 (8th Cir. 2012) (remand when district court lacks explicit immunity analysis)
- O’Neil v. City of Iowa City, 496 F.3d 915 (8th Cir. 2007) (thorough determination of immunity necessary to mean anything)
- Katosang v. Wasson-Hunt, 392 F. App’x 511 (8th Cir. 2010) (unpublished per curiam; remand for proper analysis)