Miller v. City of St. Paul, No. 15-2885 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against the City of St. Paul, its police chief, and police officer Patricia Englund, alleging violations of his First Amendment right to engage in religious speech at the 2014 Irish Fair. The district court denied plaintiff's motion for a preliminary injunction and dismissed the complaint based on lack of standing. The court affirmed the district court's dismissal of plaintiff's claims against the city, its police chief, and Englund in her official capacity based on lack of standing because plaintiff failed to allege facts that affirmatively and plausibly suggest that he was indeed subject to a credible threat of prosecution under St. Paul's policies for engaging in religious expression. The court concluded, however, that plaintiff has standing to pursue his claim against Englund in her individual capacity where 42 U.S.C. 1983 imposes liability on an official who oversteps her authority and misuses her power. In this case, Englund allegedly threatened to confiscate banners plaintiff displayed, creating a concrete threat of injury regardless of whether she also threatened to arrest him. Finally, the court affirmed the denial of plaintiff's motion for a preliminary injunction and the dismissal of his claims based on future constitutional violations.
Court Description: Murphy, Author, with Beam and Gruender, Circuit Judges] Civil case - Civil rights. The district court did not err in dismissing plaintiff's claims against the city, its police chief and an officer in their official capacities for lack of standing; however, the court erred in dismissing the claims against the officer in her individual capacity for lack of standing as Section 1983 liability can be imposed on a official who oversteps her authority or misuses her powers, and plaintiff alleged the officer threatened to confiscate his banners and signs, thereby creating a concrete threat of injury regardless of whether she also threatened to arrest him; plaintiff did not have standing to seek an injunction prohibiting officials from restricting his religious expression at future fairs as the allegations he presented are simply too speculative to support the relief.
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