Webb v. City of Maplewood, No. 17-2381 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's ruling that the City was not immune from a 42 U.S.C. 1983 suit in a putative class action alleging that the City's policy or custom of automatically issuing arrest warrants was unconstitutional. In this case, the City automatically issues an arrest warrant whenever someone ticketed for violating its traffic and vehicle laws fails to pay a fine or appear in court. The court held that municipalities, unlike States, did not enjoy a constitutionally protected immunity from suit under the Eleventh Amendment; the court rejected the City's contention that it enacted or maintained the contested practices as an arm of the State; and the court rejected the City's contention that it was also immune from suit since all of the individuals the complaint identified as participating in the contested practices were personally immune from suit. The court has long held that a municipality may be held liable for its unconstitutional policy or custom even when no official has been found personally liable for his conduct under the policy or custom.
Court Description: Arnold, Author, with Colloton and Shepherd, Circuit Judges] Civil case - Civil rights. In action alleging City's policies and practices of issuing warrants for persons who failed to pay traffic tickets and requiring them to either pay a preset bond or be jailed violated their due process and equal protection rights, the district court did not err in denying the City's motion for summary judgment based on immunity from suit, as municipalities do not enjoy a constitutionally protected immunity from suit; argument that the City is entitled to immunity under the Eleventh Amendment because the municipal court is an arm of the State and is responsible, as the real party in interest, for the disputed policies is unsupported by case law; argument that the City is immune from suit because all of the individuals the complaint identifies as participating in the contested practices are personally immune, does not mean the City cannot be liable for their unlawful acts; a municipality may be held liable for its unconstitutional policy or custom even when no official has been found personally liable for her conduct under the policy or custom.
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