Muir v. Decatur County, Iowa, No. 18-1057 (8th Cir. 2019)
Annotate this Case
The Eighth Circuit reversed the district court's denial of summary judgment to the acting county sheriff and the county in an action brought by plaintiff alleging violation of her First Amendment right to intimate association. Plaintiff contended that the sheriff had terminated her based on her marriage to her husband, who had been terminated shortly before plaintiff.
The court held that the sheriff's termination of plaintiff did not amount to a constitutional violation, because the fact that the marriage was a motivating factor in the decision to terminate plaintiff did not mean that the sheriff directly and substantially interfered with their marriage. In this case, the husband was terminated for sexually harassing other employees. Plaintiff was placed on administrative leave before the sheriff determined that her return would create a hostile work environment due to her loyalty to her husband. The court also held that, because the sheriff did not commit an unconstitutional act, no municipal liability attached to the county.
Court Description: Melloy, Author, with Loken and Erickson, Circuit Judges] Civil Case - Civil Rights. District court erred in denying qualified immunity to county and sheriff following the termination of former sheriff's wife after former sheriff was removed from office. The termination of the wife did not amount to a constitutional violation of the right to intimate association because the termination did not directly and substantially interfere with their marriage, discourage their marriage, make their marriage practically impossible or act with the goal of poisoning their marriage, and was nothing more than a collateral effect on her marriage. Because there was no unconstitutional act, there was no municipal liability either.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.