Sparks v. Shaver, No. 20-2752 (8th Cir. 2021)
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Plaintiff filed suit against the City of Pierre, South Dakota, and one of its police officers, Matthew Shaver, under 42 U.S.C. 1983 in federal district court, alleging that his Fourth Amendment rights were violated.
The Eighth Circuit affirmed the district court's holding that defendant was collaterally estopped from relitigating his claim because he had already litigated the Fourth Amendment issue before the South Dakota trial court in the criminal proceedings against him. In this case, during criminal proceedings in a South Dakota trial court, defendant moved to suppress certain evidence as being obtained in violation of the Fourth Amendment. After the trial court denied defendant's motion, he then pleaded nolo contendere and did not appeal the suppression ruling. Plaintiff later filed his section 1983 action. Therefore, the court concluded that there was a final judgment on the merits for the purpose of collateral estoppel.
Court Description: [Smith, Author, with Shepherd and Grasz, Circuit Judges] Civil case - Civil rights. In this action plaintiff sued the City of Pierre, South Dakota and one of its police officers under Section 1983 alleging a search warrant compelling his forced catheterization violated his Fourth Amendment rights; in the state criminal case which followed the search, plaintiff unsuccessfully challenged the admission of the evidence obtained under the warrant, and his motion to suppress was denied; plaintiff later pleaded nolo contendere to the criminal charges and did not appeal the suppression ruling. Held: the district court did not err in holding that plaintiff was collaterally estopped from re-litigating his claim because he had already litigated the Fourth Amendment issue before the South Dakota trial court in the criminal proceeding against him.
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