Rasheen Aldridge v. City of St. Louis, Missouri, 75 F.4th 895

Protests followed a police officer’s acquittal; during one downtown protest officers arrested and led away a protestor while a crowd followed.
Officer William Olsten, holding a pepper-spray fogger, exchanged words with nearby protestors (notably Amir Brandy); shortly after an unidentified person shouted something indistinct, Olsten swept pepper spray across the crowd.
Appellants Rasheen Aldridge, Jazmin Franks, and Crystal Brown were among those pepper-sprayed; none were arrested after the spray.
Each sued Officer Olsten, Police Chief John Hayden, and the City of St. Louis alleging First Amendment retaliation, excessive force, Monell municipal liability, and state-law claims.
The district court granted summary judgment for the City Officials on all federal claims (including retaliation and excessive force where relevant) and declined supplemental jurisdiction over state-law claims; the plaintiffs appealed.
The Eighth Circuit reviewed de novo under qualified-immunity principles and affirmed the district court in a consolidated opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment retaliation (did Olsten spray in retaliation for protected protest?)	Olsten singled out and sprayed appellants for questioning/criticizing police, demonstrating retaliatory animus.	Olsten sprayed in response to a perceived threat from an unidentified shout and used a sweeping motion for crowd control, not to single out protesters.	Affirmed for defendants: plaintiffs failed to show a causal connection or that they were singled out due to protected speech.
Monell municipal liability (can City be liable absent individual liability?)	City policies/training allowed retaliatory or excessive use of force, making City liable.	Municipal liability requires an underlying finding of individual constitutional violation; no individual liability here so no Monell liability.	Affirmed for City: no municipal liability because plaintiffs failed to prove individual constitutional violations.
Supplemental jurisdiction over state-law claims (should district court have retained them?)	Plaintiffs urged reinstatement of state-law claims after federal claims were dismissed.	District court properly declined jurisdiction; federal claims eliminated pretrial and no compelling reason to retain state claims.	Affirmed: court did not abuse discretion in declining supplemental jurisdiction.

Nieves v. Bartlett, 139 S. Ct. 1715 (retaliation claims require a causal connection between protected conduct and adverse action)
Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (municipal liability under § 1983 requires a municipal policy or custom causing the violation)
Quraishi v. St. Charles Cnty., 986 F.3d 831 (8th Cir.) (singling out specific individuals for force can create a jury question on retaliatory motive)
Baribeau v. City of Minneapolis, 596 F.3d 465 (8th Cir. 2010) (retaliation requires showing the plaintiff was singled out due to protected expression)
Mitchell v. Kirchmeier, 28 F.4th 888 (8th Cir.) (retaliation requires proof officer acted from retaliatory animus even if force was unreasonable)
Connick v. Thompson, 563 U.S. 51 (municipalities are liable only for their own policies or customs, not vicarious employee actions)
Scott v. Harris, 550 U.S. 372 (summary-judgment standard where video evidence sharply contradicts plaintiff’s version of events)
Laney v. City of St. Louis, 56 F.4th 1153 (8th Cir.) (an obvious alternative, nonretaliatory explanation for an officer’s action undercuts retaliation claims)