Watson v. Maplewood, Missouri, City of
4:17-cv-01268
E.D. Mo.Nov 1, 2017Background
- Plaintiff Rosetta Watson lived in Maplewood, Missouri (2010–2012) in a Section 8–subsidized unit and experienced multiple incidents of domestic violence and police calls involving her ex‑boyfriend.
- Maplewood’s ordinances define certain repeated incidents (including domestic violence/peace disturbances generating police calls) as a "nuisance" and authorize a hearing officer to hold a hearing, issue findings, and abate nuisances including revocation of occupancy permits for up to six months.
- The City scheduled a nuisance hearing for Watson; Anthony Traxler was appointed hearing officer, Watson attended pro se, testimony (including police testimony) was taken on several incidents, and Traxler issued written Findings, Conclusions and an Order revoking Watson’s occupancy permit for six months.
- Chief of Police Stephen Kruse sent a letter enforcing the hearing officer’s order directing Watson to vacate; City Manager Martin Corcoran authorized Traxler to serve as hearing officer.
- Watson sued the City and the individual defendants alleging violations of First Amendment (speech/petition), Equal Protection, Right to Travel, Due Process, state constitutional claims, and statutory preemption under the Violence Against Women Act. The individual defendants moved to dismiss, asserting absolute immunity (or alternatively qualified immunity). The court addressed absolute immunity and dismissed Traxler, Corcoran, and Kruse.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether hearing officer (Traxler) is entitled to absolute immunity for conducting nuisance hearing and issuing order | Traxler acted unfairly (served as prosecutor and judge) and violated constitutional rights by enforcing ordinance against Watson for incidents where she was a victim; thus not immune | Traxler performed a quasi‑judicial/adjudicatory function in a contested MAPA‑style hearing with notice, testimony under oath, right to counsel, written findings, and appeal; absolute immunity applies | Court: Traxler entitled to absolute immunity; claims against him dismissed |
| Whether City Manager (Corcoran) is entitled to absolute immunity for appointing the hearing officer | Corcoran’s authorization contributed to unconstitutional enforcement | Appointment of hearing officer is a protected administrative function analogous to actions previously held immune | Court: Corcoran entitled to absolute immunity; dismissed |
| Whether Chief of Police (Kruse) is entitled to absolute immunity for sending enforcement/vacate letter | Kruse’s letter was enforcement of the hearing officer’s order but plaintiff argues actions harmed her and were part of unconstitutional conduct | Acting to carry out a facially valid quasi‑judicial order is a ministerial act protected by absolute/quasi‑judicial immunity | Court: Kruse entitled to absolute immunity for ministerial enforcement; dismissed |
| Whether procedural safeguards were sufficient to negate absolute immunity claim | Watson contends procedural defects (bias, prosecutor/judge role, missing cross‑examination) made proceeding non‑quasi‑judicial | City points to statutory/ordinance safeguards (notice, hearing, right to counsel, oath, written findings, appeal) showing quasi‑judicial character | Court: Safeguards sufficient; proceeding characterized as quasi‑judicial supporting absolute immunity |
Key Cases Cited
- Brown v. Griesenauer, 970 F.2d 431 (8th Cir. 1992) (distinguishes absolute vs. qualified immunity for nonjudicial officials performing adjudicatory functions)
- Butz v. Economou, 438 U.S. 478 (1978) (factors characterizing the judicial process for immunity analysis)
- Cleavinger v. Saxner, 474 U.S. 193 (1985) (discusses line between absolute and qualified immunity for administrative adjudicators)
- Antoine v. Byers & Anderson, 508 U.S. 429 (1993) (burden on proponent of absolute immunity; functional approach)
- Penn v. United States, 335 F.3d 786 (8th Cir. 2003) (officers enforcing facially valid orders are immune for ministerial acts)
- Krueger v. Lyng, 4 F.3d 653 (8th Cir. 1993) (upholding absolute immunity for certain administrative actors in similar contexts)