S.M. v. Lincoln County, Missouri
2017 U.S. App. LEXIS 21316
| 8th Cir. | 2017Background
- Plaintiffs (former Drug Court participants S.M., L.M., K.W., K.S.) sued Lincoln County under 42 U.S.C. § 1983 after Scott Edwards, the County’s Drug Court “tracker,” repeatedly sexually assaulted them while performing tracker duties.
- Edwards’s tracker role (per the Drug Court MOU and Policies) included night curfew/home visits, on-site UA tests, searches, reporting to the Drug Court team, and transporting/taking participants into custody as sanctions.
- Edwards exploited his authority—committing assaults in jail, during curfew visits, during strip searches, and while transporting participants; some victims feared reporting because Edwards could influence Drug Court sanctions.
- A jury found Lincoln County (through the Lincoln County Sheriff as policy maker) deliberately indifferent in supervising Edwards and awarded substantial compensatory damages to plaintiffs; the district court denied the County’s post-verdict JMOL/new-trial motions.
- On appeal, the Eighth Circuit reviewed whether the evidence supported municipal liability for failure to supervise under the Canton/Monell deliberate-indifference standard and whether damages were supported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lincoln County can be liable under Monell for failing to supervise Edwards | County’s MOU and Drug Court practice made Sheriff responsible; failure to supervise was so obvious that it was deliberately indifferent and caused the violations | Sheriff (Krigbaum) lacked actual knowledge; Drug Court or other agencies supervised Edwards; insufficient evidence linking County to notice or causation | Jury verdict upheld: sufficient evidence for a reasonable jury to find the Sheriff (County) had supervisory responsibility, deliberate indifference, and causation |
| Whether lack of supervision was the “moving force” behind constitutional violations | Tracker’s duties and unsupervised opportunities made sexual abuse likely; modest supervision would have deterred him | County argued assaults could occur despite supervision; plaintiffs didn’t identify specific procedures that would have prevented assaults | Held that evidence permitted inference that inadequate supervision was the moving force enabling Edwards’s abuse |
| Whether the district court abused its discretion by denying a new trial based on excessive/unsupported damages | Plaintiffs’ testimony about emotional trauma, recorded and plea-admitted assaults provided competent evidence to support emotional distress awards | County argued no detailed financial or expert proof supported large awards | Denial of new trial affirmed: compensatory awards for emotional distress may rest on plaintiff testimony and the record supported genuine injury |
| Proper standard for municipal deliberate-indifference in multi-agency Drug Court context | Plaintiffs: an objective deliberate-indifference standard applies to municipal liability; notice could be established by obviousness to Drug Court team members | County emphasized differences between individual-qualified-immunity subjective standard and municipal objective standard and contested notice attribution | Court applied objective deliberate-indifference standard and, given the unobjected-to jury instructions and evidence, affirmed liability |
Key Cases Cited
- S.M. v. Krigbaum, 808 F.3d 335 (8th Cir. 2015) (individual-qualified-immunity analysis and recognition of tracker misconduct)
- Szabla v. City of Brooklyn Park, 486 F.3d 385 (8th Cir. 2007) (Monell/municipal liability limits; not respondeat superior)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires action pursuant to official policy)
- Bd. of Cty. Comm’rs v. Brown, 520 U.S. 397 (1997) (rigorous culpability/causation standards for municipal inaction; deliberate indifference definition)
- City of Canton v. Harris, 489 U.S. 378 (1989) (failure-to-train/supervise municipal-liability standard: deliberate indifference and moving force)
- Connick v. Thompson, 563 U.S. 51 (2011) (pattern ordinarily required to show deliberate indifference in training/supervision claims)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standards in constitutional claims)
- Jackson v. City of St. Louis, 220 F.3d 894 (8th Cir. 2000) (standard for upholding jury verdict on sufficiency grounds)
- Parrish v. Ball, 594 F.3d 993 (8th Cir. 2010) (moving force causation in municipal-liability context)
- Bennett v. Riceland Foods, Inc., 721 F.3d 546 (8th Cir. 2013) (emotional distress damages can be supported by plaintiff testimony)