Evans v. City of Helena-West Helena, No. 17-2005 (8th Cir. 2019)
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Plaintiff appealed the district court's dismissal of her 42 U.S.C. 1983 action alleging that the City deprived her of her constitutional rights. Plaintiff's amended complaint alleged that she was arrested, her car was towed, and she was held at the police station until it was discovered that she had paid certain fines.
The Eighth Circuit held that the district court erred because, whether or not the clerk had absolute or qualified immunity, that immunity did not foreclose an action against the City if the complaint adequately alleged an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee. Although the record has not been developed with respect to the clerk's duties and responsibilities, the source of the clerk's pay, or the degree that state or local officials exercised over the clerk, the court held that the complaint at least stated a plausible claim of wrongdoing. Therefore, the court remanded for further proceedings.
Court Description: Colloton, Author, with Beam and Grasz, Circuit Judges] Civil case - Civil rights. In action alleging the Phillips County District Court clerk's office failed to document plaintiff's payment of certain fines and requested her arrest, thereby depriving her of her liberty and property in violation of her due process rights, the district court erred in dismissing the action against the City of West Helena; even if the clerk has absolute or qualified immunity, that immunity does not foreclose an action against the City if the complaint adequately alleges an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee; as to the district court's other rationale for dismissal - that the clerk is a state government official whose actions are not attributable to the City - the record has not been developed, at this state of the case, regarding the clerk's duties, source of salary and the degree of control exercised by state and City officials; the complaint states a plausible claim that the clerk was a city official, in which case the City could be accountable; it was error, therefore, to dismiss the complaint.
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