Ramona Evans v. City of Helena-West Helena, AR, 912 F.3d 1145

Evans alleged that Phillips County District Court clerk failed to record fine payments, leading to a warrant, her arrest, towing of her car, and temporary detention until payments were verified.
Complaint claimed the clerk’s failures reflected a municipal "practice, custom and habit" and unconstitutional city policies causing deprivations of liberty and property under 42 U.S.C. § 1983 and the Fourteenth Amendment.
The arrest date window in the complaint was between July 18, 2013 and July 15, 2016.
The district court dismissed for failure to state a claim, reasoning the clerk and district court were state officials not employed by or amenable to suit against the City.
On appeal, the Eighth Circuit held the district court erred: a municipality (the City) may be sued, and whether the clerk was a city or state official depends on state-law definitions of the clerk’s functions and the local facts (control, funding, hiring).
The Court concluded Evans plausibly alleged the clerk was a city official during the relevant period (pre-2017), so dismissal was improper and the case was remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the City can be sued under § 1983 for the clerk’s actions	Evans: clerk’s failure reflected a municipal policy/custom causing constitutional deprivation	City: clerk and district court were state actors after Amendment 80; acts not attributable to City	Reversed: municipality can be sued; whether clerk was a city or state official is a factual/legal question not resolved at pleading stage
Whether clerk’s immunity defeats municipal liability	Evans: City liable if unconstitutional policy/custom exists regardless of clerk’s personal immunity	City: immunity or state status of clerk prevents attribution to City	Court: clerk’s personal immunity does not preclude municipal liability if complaint alleges unconstitutional policy/action by clerk
Proper attribution of clerk’s actions (state vs local) under McMillian	Evans: complaint alleges local employment, pay, and City control of clerk and staff	City: Amendment 80 placed district courts and clerks into judicial (state) department	Court: relevant statutory implementation shows Phillips County courts remained locally funded/organized during period; factual record needed to determine attribution
Sufficiency of complaint at pleading stage	Evans: pleaded facts suggesting clerk was city employee and municipal policy/custom	City: argued dismissal proper due to state function argument	Court: complaint plausibly alleged city culpability; dismissal for those grounds was error

Alden v. Maine, 527 U.S. 706 (state sovereign immunity is limited and municipalities lack such immunity)
Owen v. City of Independence, 445 U.S. 622 (municipal liability under § 1983 requires an unconstitutional municipal policy or custom)
McMillian v. Monroe County, 520 U.S. 781 (whether an official is a state or local actor depends on the function under state law)
Webb v. City of Maplewood, 889 F.3d 483 (8th Cir. 2018) (municipal liability can attach even if the individual actor may have personal immunity)