Mary Meier v. St. Louis, Missouri, City of
934 F.3d 824
8th Cir.2019Background
- In Dec 2015 SLMPD reported Mary Meier’s truck as “wanted” on REJIS after a hit-and-run investigation; REJIS is a regional law-enforcement information-sharing network.
- On March 17, 2016, Maryland Heights PD located the truck, arrested occupants, and directed Doc’s Towing to tow it after seeing the REJIS wanted report. Doc’s notated a “hold” and stored the truck.
- SLMPD sent REJIS messages indicating the vehicle was located and asked to be notified; it later instructed that the owner be told to contact SLMPD’s First District Detective Bureau for release.
- Meier attempted retrieval on March 18 but was told SLMPD had a hold; after counsel obtained an SLMPD “release order” on April 29, Doc’s released the truck upon payment of towing/storage fees.
- Meier sued under 42 U.S.C. § 1983 alleging Fourth/Fourteenth Amendment violations; district court granted summary judgment for the City and Doc’s, finding no municipal policy or color-of-law basis. The Eighth Circuit reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability (Monell) — whether St. Louis had an official or unwritten policy causing seizure | Meier: SLMPD has an unwritten, widespread practice of reporting vehicles as “wanted” on REJIS to detain them without a warrant | St. Louis: Wanted reports merely authorize towing; wanted ≠ hold; no policy caused the seizure | Reversed: Evidence (testimony of SLMPD personnel and REJIS practice) permits a jury to find an unwritten policy and causal link |
| Existence of a continuing, widespread unconstitutional custom | Meier: Testimony (defense attorney, REJIS trainer, SLMPD captain) shows regular use of wanted reports as de facto holds | St. Louis: No formal hold was issued; isolated or mistaken actions by others | Held for Meier: Evidence could show continuing, widespread practice and policymaker awareness |
| Requirement to sue individual employee for municipal liability | St. Louis: Without an adjudicated constitutional violation by a city employee, City cannot be liable | Meier: City may be liable under Monell without suing individual employees if municipal policy caused violation | Court: Municipal liability may be predicated on employee action without naming the individual; plaintiff need not sue the employee |
| Whether Doc’s Towing acted under color of law | Meier: Doc’s willfully participated in SLMPD’s detention, followed a no-release-until-police rule, and relied on SLMPD’s hold instruction | Doc’s: No close nexus to the City; merely a private towing/storage company | Reversed: Evidence could show a close nexus / mutual understanding making Doc’s actions fairly attributable to the government |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires action pursuant to official policy)
- Smith v. Insley’s Inc., 499 F.3d 875 (summary judgment standard; private actor color-of-law analysis)
- Szabla v. City of Brooklyn Park, 486 F.3d 385 (Monell standards referenced)
- Brewington v. Keener, 902 F.3d 796 (elements to prove unwritten municipal policy)
- Webb v. City of Maplewood, 889 F.3d 483 (municipal liability may exist absent suit against individual employee)
- Lugar v. Edmondson Oil Co., 547 U.S. 922 (fairly attributable test for state action)
- Wickersham v. City of Columbia, 481 F.3d 591 (private party may be state actor when willful participant in joint activity)
- Magee v. Trs. of Hamline Univ., 747 F.3d 532 (mutual understanding/meeting of the minds relevant to color-of-law determination)