Lewis v. Gardner, No. 18-2555 (8th Cir. 2019)
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Plaintiff filed suit alleging that defendants were responsible for his delayed release from jail following the dismissal of criminal charges against him. The Eighth Circuit reversed the district court's denial of qualified immunity to the St. Louis Circuit Attorney, holding that she did not violate plaintiff's constitutional rights because the law did not clearly establish that the attorney, or prosecutors in her office, must go beyond the filing of a nolle prosequi to ensure the release of those against whom no charges are pending. Even assuming that the attorney had such a duty, plaintiff has not actually alleged that the attorney did not satisfy that responsibility.
The court also held that plaintiff's false-imprisonment claim against the attorney should be dismissed where the complaint did not plausibly show that the attorney was personally involved in plaintiff's delayed release. Accordingly, the court remanded for further proceedings.
Court Description: Arnold, Author, with Smith, Chief Judge, and Kelly, Circuit Judge] Civil case - Civil rights. In action alleging plaintiff's delayed release from custody after charges were dismissed against him, the City of St. Louis prosecuting attorney moved for summary judgment based on qualified immunity; the question for determination is whether the city's prosecutors must go beyond the filing of a nolle prosequi to ensure the release of a person against whom no charges are pending; there is no authority for placing such a responsibility on the prosecuting attorney or her office and there was no basis for finding she had violated plaintiff's constitutional rights; even assuming such a legal responsibility existed, plaintiff had not actually alleged that the prosecutor had not satisfied that responsibility; additionally, plaintiff's claim for false-imprisonment against the prosecutor should also be dismissed as the court's conclusion that the prosecutor was not personally involved in the decision to delay plaintiff's release necessarily requires dismissal since, under Missouri law, a claim for false imprisonment requires personal involvement of the defendant.
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