S.L. Ex Rel. Lenderman v. St. Louis Metropolitan Police Department Board of Police Commissioners
2013 U.S. App. LEXIS 16101
| 8th Cir. | 2013Background
- S.L. was arrested for trespassing by SLMPD officers Lorthridge and Arnold, with Arnold being Arnold’s son’s girlfriend; arrest followed a suggestion to arrest to avoid a ride-home problem.
- The arrest report underwent multiple revisions; the fifth draft included a false witness, false location, and a fabricated victim; Arnold’s involvement was initially concealed.
- Isshawn-O’Quinn, new in the district, approved the fifth report after being advised by Lorthridge to be creative, and Arnold’s potential involvement was downplayed.
- An internal affairs investigation followed; Harris, head of internal affairs, allegedly received confidential information and shared it with Arnold; Arnold and Lorthridge gave false statements in interviews.
- S.L.’s injuries included a punctured lung and significant emotional distress; internal discipline resulted in Arnold’s termination and Isshawn-O’Quinn’s discipline, while Lorthridge resigned.
- S.L. sued under §1983 for false arrest and conspiracy; district court denied qualified immunity to the officers involved and denied summary judgment on municipal claims, which the Board and others challenged.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Harris and Isshawn-O’Quinn violated §1983 via conspiracy | S.L. contends Harris and Isshawn-O’Quinn conspired to cover up the false arrest. | Harris and Isshawn-O’Quinn argue qualified immunity shields them from conspiracy liability in the absence of a clearly established right. | Conspiracy liability shown; no qualified immunity |
| Whether the district court correctly denied qualified immunity on the conspiracy claim | S.L. alleges overt acts and injury from the conspiracy by Harris and Isshawn-O’Quinn. | Defendants contend their conduct did not violate clearly established rights or warrant denial of immunity. | The right was clearly established; immunity denied |
| Whether the Board, Isom, and Harris’s municipal liability claims are reviewable on appeal via pendent jurisdiction | Plaintiff sought review of municipal liability claims intertwined with the qualified immunity ruling. | Defendants argue pendent jurisdiction is appropriate due to intertwined issues. | Lack of pendent-jurisdiction; claims dismissed for lack of jurisdiction |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (establishes qualified immunity framework for government officials)
- Mitchum v. Foster, 407 U.S. 225 (U.S. 1972) (purpose of §1983 to protect rights against state action)
- Nance v. Sammis, 586 F.3d 604 (8th Cir. 2009) (standard for reviewing conspiracy claims and qualified immunity)
- Mettler v. Whitledge, 165 F.3d 1197 (8th Cir. 1999) (conspiracy risk and clearly established rights in police misconduct)
- Lockridge v. Bd. of Trs. of Univ. of Ark., 315 F.3d 1005 (8th Cir. 2003) (standard for reviewing district-court summary-judgment decisions on immunity)
- Westborough Mall, Inc. v. City of Cape Girardeau, 693 F.2d 733 (8th Cir. 1982) (causation between police conduct and injuries in §1983 context)
- Scheeler v. City of St. Cloud, 402 F.3d 826 (8th Cir. 2005) (denial-of-access claims; backward-looking vs forward-looking analysis)
- Harbury v. Christopher, 536 U.S. 403 (U.S. 2002) (backward-looking denial-of-access claim requirements under Harbury)