Maxine Veatch v. Bartels Lutheran Home
2010 U.S. App. LEXIS 26270
| 8th Cir. | 2010Background
- Veatch was arrested by Sgt. Leonard for assaulting her mother at Woodland Terrace after Bartels staff reported bruising.
- District court granted summary judgment for Leonard and the City on the § 1983 claim and dismissed state-law claims without prejudice.
- Veatch alleged a Fourth Amendment violation and City failure to train Leonard under § 1983.
- Leonard investigated the incident via interviews with Bartels staff and reviewed a doctor’s report of bruising; he had probable cause.
- Leonard arrested Veatch without witnessing the alleged assault; a magistrate later released her on his own recognizance; Veatch was charged and found not guilty at trial.
- Court addresses whether the arrest violated the Fourth Amendment and whether the City can be liable under Monell for failure to train.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless arrest violated the Fourth Amendment | Veatch contends arrest outside presence violated rights | Leonard had probable cause; presence rule not clearly established | Probable cause supported arrest; presence requirement not clearly established; no Fourth Amendment violation shown |
| Monell liability for training related to misdemeanor arrests | City failed to train on lawful misdemeanor arrests | No pattern or deliberate indifference shown; single incident insufficient | No deliberate indifference; no Monell liability |
| Whether Leonard’s § 1983 claim against him was properly dismissed as redundant | Individual-capacity claim should proceed | Treat as official-capacity claim; redundant to City | Dismissal proper; suit effectively against City |
Key Cases Cited
- Atwater v. City of Lago Vista, 532 U.S. 318 (2001) (arrest of misdemeanor may be based on probable cause; not require presence)
- Brown v. Bd. of County Comm’rs, 520 U.S. 397 (1997) (deliberate indifference requires cognizable fault and causal link)
- City of Canton v. Harris, 489 U.S. 378 (1989) (establishes deliberate indifference standard for municipal liability)
- Bd. of Cnty. Comm’rs v. Brown, 520 U.S. 397 (1997) (reiterates municipal liability framework and need for fault and causation)
- City of Los Angeles v. Heller, 475 U.S. 796 (1986) (policy-based liability considerations for municipalities)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (establishes municipal liability for official policy causing constitutional tort)
- Draper v. United States, 358 U.S. 307 (1959) (probable-cause standard; allows hearsay in probable-cause determinations)
- Leppert v. United States, 408 F.3d 1039 (8th Cir. 2005) (supports admissibility of information gathered during investigation for probable cause)
- Woods v. City of Chicago, 234 F.3d 979 (7th Cir. 2000) (discusses absence of in-presence requirement for misdemeanor arrests)
- Artis v. Francis Howell N. Band Booster Ass’n, 161 F.3d 1178 (8th Cir. 1998) (corporate/official capacity considerations in § 1983 context)
- Dodd v. James, 623 F.3d 563 (8th Cir. 2010) (standard of review for summary judgment in § 1983 cases)