Teagan v. City of McDonough, No. 18-11060 (11th Cir. 2020)Annotate this Case
Plaintiff filed suit against the city, alleging claims under 42 U.S.C. 1983 for violations of her Fourth, Sixth, and Fourteenth Amendment rights, and a state-law claim under Georgia law for false imprisonment. Plaintiff's claims stemmed from her misdemeanor proceedings in municipal court for failure to maintain automobile liability insurance as required by Georgia law.
The Eleventh Circuit affirmed the district court's grant of summary judgment on plaintiff's section 1983 claims, holding that the municipal court was exercising its judicial power under Georgia law to adjudicate a state-law offense, not a violation of a city or county ordinance, and thus was not acting on behalf of the city. However, the court held that the district court failed to address plaintiff's state-law claim for false imprisonment and therefore remanded for further proceedings on that claim. The court stated that, because there are some Georgia cases suggesting that the invalidity of a warrant may permit a false imprisonment claim, it was best for the district court to consider that claim in the first instance.