Tamela Muir v. Decatur County, Iowa, 917 F.3d 1050

Tamela Muir was an at-will jailer/dispatcher for the Decatur County Sheriff’s Office; her husband Bert was Sheriff until he resigned after removal proceedings based on sexual-harassment complaints.
Thomas Miller, hired to prepare a petition to remove Bert, advised acting Sheriff Ben Boswell to place Tamela on leave because other employees who signed affidavits might be uncomfortable working with her.
Boswell placed Tamela on indefinite administrative leave on March 4, 2016, then terminated her on April 21, 2016, citing concerns that her return would undermine trust and create a hostile work environment due to loyalties to her husband.
Tamela sued under 42 U.S.C. § 1983, alleging Boswell and Decatur County violated her First Amendment right of intimate association by firing her because she was married to Bert.
The district court denied summary judgment, finding disputed facts about whether the marriage motivated the termination and whether municipal liability could attach; the county and Boswell appealed qualified immunity and municipal-liability rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether terminating Tamela for her marriage to Bert violated her First Amendment right of intimate association	Muir: Boswell fired her because she was married to Bert, directly interfering with the right to intimate association	Boswell: Even if marriage was a motivating factor, termination did not directly and substantially interfere with the marriage—only a collateral employment effect	No constitutional violation: termination did not significantly discourage, make the marriage impossible, or aim to poison it (Singleton controls)
Whether Boswell is entitled to qualified immunity	Muir: Right to intimate association was clearly established and Boswell’s actions violated it	Boswell: No clearly established constitutional violation occurred, so qualified immunity applies	Qualified immunity applies because no constitutional violation was shown under controlling precedent
Whether Decatur County can be held liable municipally for Boswell’s action	Muir: County liable if Boswell’s act was unconstitutional or reflected a custom/policy	County: Municipal liability requires an underlying unconstitutional act by an employee	No municipal liability because there was no unconstitutional act by Boswell, so County cannot be held liable

Singleton v. Cecil, 133 F.3d 631 (8th Cir. 1998) (framework for when government action interferes with right of intimate association/marriage)
Roberts v. United States Jaycees, 468 U.S. 609 (U.S. 1984) (scope of the right of intimate association)
Shannon v. Koehler, 616 F.3d 855 (8th Cir. 2010) (limits of appellate review from denial of qualified immunity)
Nord v. Walsh County, 757 F.3d 734 (8th Cir. 2014) (two-step qualified immunity analysis and standard of review)
Webb v. City of Maplewood, 889 F.3d 483 (8th Cir. 2018) (municipal liability requires an underlying unconstitutional act by an employee)
Tyler v. City of Mountain Home, 72 F.3d 568 (8th Cir. 1995) (deference to law-enforcement personnel decisions regarding discipline and personnel)