Robbins v. Becker,, No. 14-1435 (8th Cir. 2015)
Annotate this CaseThe Robbinses provide towing and wrecker services along the I-44 corridor in eastern Missouri. State Highway Patrol (MSHP) Troops C and I, pursuant to MSHP policy, used a “rotation list” of approved towing and wrecking companies to determine which company to call to the scene of a disabled vehicle if the vehicle owner had no preference. The Robbinses were on both lists until they were removed, reportedly because Robbins had been charged with shooting at a competitor’s truck in 1999. The Robbinses alleged the criminal charge resulted from a “sham investigation” and that their competitor used a friendship with an MSHP officer, with whom Robbins had had a confrontation, to harm the Robbinses’ business. A jury acquitted Robbins, but they were never reinstated to either list. In 2005, the Robbinses sued the MSHP. The state court determined the MSHP lacked statutory authority to create a rotation list. In 2010, the Robbinses sued officers in their individual capacities, alleging due process and equal protection violations and conspiracy to violate those rights under 42 U.S.C. 1983 and violations of the Sherman Act, 15 U.S.C. 1, 2, claiming that the officers conspired to deny them work and disparaged their business. The Eighth Circuit affirmed summary judgment in favor of the officers.
Court Description: Riley, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. For the court's prior opinion in the matter, see Robbins v. Becker, 715 F.3d 691 (8th Cir. 2013). In action alleging the defendant state troopers and towing companies conspired to interfere with plaintiffs' towing business, the district court did not err in finding plaintiffs did not have a legitimate claim of entitlement to any particular towing work and could not establish a constitutionally-protected property right; nor did their claims establish violation of a liberty interest; in order to establish a "class-of-one" equal protection claim, a plaintiff must provide a specific and detailed account of the nature of the preferred treatment of the favored class, especially where the state actors exercise broad discretion to balance a number of legitimate considerations, and plaintiffs failed to meet this exacting standard; absent a constitutional violation, plaintiffs could not state an actionable conspiracy claim; with respect to the claim that the officers conspired with other towing companies to restrain and monopolize trade in violation of Sections 1 and 2 of the Sherman Act, the plaintiffs failed to produce any evidence of such a conspiracy. Judge Loken, concurring.
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