Rasheen Aldridge v. City of St. Louis, Missouri, No. 22-1735 (8th Cir. 2023)
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Appellants were each pepper-sprayed by Police Officer William Olsten while participating in a protest in downtown St. Louis. Each of them sued various officials, alleging First Amendment retaliation and excessive force claims, as well as various other federal and state law claims. In each case, the district court granted summary judgment in favor of the city officials on all the federal claims and declined supplemental jurisdiction on the state law claims.
The Eighth Circuit consolidated the cases and affirmed. The court explained that here, Appellants admit that “every other non-police officer in the vicinity was actively involved in a protest” and that the officer “moved his arm side to side and indiscriminately sprayed numerous protestors.” One cannot simultaneously single out Appellants and “indiscriminately” spray the crowd. And there is no evidence in the record that either Appellant had any interaction with the officer or that the officer was aware of their presence, or that either did anything to differentiate themselves from the other protestors in the crowd. While one Appellant argued she was filming the protest, there is no evidence that the officer observed her filming or deployed pepper spray in retaliation for her doing so. Regardless of whether the officer’s action was appropriate or reasonable under the circumstances, the lack of evidence causally connecting the officer’s adverse action of using pepper spray to Appellants’ protected expression is fatal to the retaliation claims.
Court Description: [Grasz, Author, with Melloy and Kobes, Circuit Judges] Civil case - Civil rights. Plaintiffs were pepper sprayed during a protest in downtown St. Louis and sued the officer who sprayed them, the police chief and the City of St. Louis, alleging First Amendment retaliation and excessive force, among other federal and state law claims. The district court granted defendants summary judgment on the federal law claims and declined to exercise supplemental jurisdiction on the state law claims. Plaintiffs appeal. There was no evidence causally connecting the officer's use of pepper spray with the plaintiffs' protected expression, and this is fatal to their First Amendment retaliation claim; in the absence of a constitutional violation, the district court correctly granted the City's motion for summary judgment on plaintiffs' Monell claims; the district court did not abuse its discretion in declining to exercise supplemental jurisdiction on plaintiffs' state law claims.
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