Mary Meier v. City of St. Louis, Missouri, 78 F.4th 1052

Background

In Dec. 2015 an SLMPD officer entered a "wanted" report for Meier’s Ford truck into the REJIS regional database after a hit-and-run investigation.
On Mar. 17, 2016 an officer from Maryland Heights (MHPD) located the truck, saw the REJIS wanted report, arrested the occupants for unrelated reasons, and instructed Doc’s Towing to tow the truck and place a "hold."
Doc’s Towing retained the truck and would not release it; SLMPD told MHPD the wanted report remained active and instructed that the owner/driver must report to SLMPD to obtain release.
Meier and her counsel repeatedly contacted SLMPD; SLMPD eventually issued a written "release order" and Doc’s Towing released the truck on Apr. 29 after nearly two months; Meier paid storage fees.
Meier sued under 42 U.S.C. § 1983 alleging Fourth Amendment unreasonable seizure and Fourteenth Amendment due process violations; on remand from this court’s earlier opinion (Meier I), she settled with Doc’s Towing and tried the City of St. Louis case to a jury.
The district court granted JMOL for the City on the unreasonable seizure claim; the jury found for Meier on the due process (Monell) claim and awarded $7,500, reduced by a $2,000 set-off from the prior settlement with Doc’s Towing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doc’s Towing’s retention of the truck was state action fairly attributable to the City	SLMPD’s wanted report, active confirmation, instructions to advise owner, and issuance of release order show a close nexus to the City	Towing was private action by Doc’s Towing and MHPD; not attributable to SLMPD/City	A reasonable jury could find a close nexus; state action fairly attributable to the City — verdict affirmed
Whether City had a municipal custom causing a due process violation (Monell)	SLMPD had a pervasive practice of entering wanted reports to detain vehicles and requiring owners to report to police for release, depriving owners of meaningful process	No evidence of a continuing widespread custom; isolated acts only	Sufficient evidence of a custom and causation for a Monell due process claim; jury verdict affirmed
Whether JMOL on unreasonable seizure was proper	Meier argued JMOL should be reversed and the seizure claim submitted to jury	City maintained JMOL was proper and any relief would duplicate jury damages	Court declined to reverse JMOL because Meier showed no additional relief beyond the jury award; JMOL affirmed
Proper set-off of settlement proceeds from Doc’s Towing	Meier: only amounts in settlement attributable to the district-court claims should offset jury award (actual damages $2,000)	City: seeks a larger offset (including more of the settlement and possibly attorney’s fees)	District court did not abuse discretion in offsetting only the $2,000 attributable to the claims; attorney’s fees not offset now but may be addressed later

Key Cases Cited

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires an official policy or custom)
Lugar v. Edmondson Oil Co., 457 U.S. 922 (state-action requirement and the "fairly attributable" test)
Fuentes v. Shevin, 407 U.S. 67 (due process requires notice and meaningful opportunity to be heard)
Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (due process principles for property deprivations)
Meier v. City of St. Louis, 934 F.3d 824 (8th Cir. 2019) (prior reversal of summary judgment; evidence could support municipal liability)
Wickersham v. City of Columbia, 481 F.3d 591 (8th Cir. 2007) (close-nexus/state-action analysis)
Brewington v. Keener, 902 F.3d 796 (8th Cir. 2018) (elements for proving municipal custom)
Corwin v. City of Independence, 829 F.3d 695 (8th Cir. 2016) (Monell proof standards)
Jacobson Warehouse Co. v. Schnuck Markets, Inc., 13 F.4th 659 (standard of review for JMOL; view evidence in light most favorable to verdict)
Hopman v. Union Pac. R.R., 68 F.4th 394 (JMOL requires no reasonable jury could find for nonmoving party)
Budinich v. Becton Dickinson & Co., 486 U.S. 196 (attorney’s fees are generally not part of the merits damages)
Continental Indem. Co. v. IPFS of N.Y., LLC, 7 F.4th 713 (abuse-of-discretion review of post-judgment motions)