Ridgell v. City of Pine Bluff, No. 18-2663 (8th Cir. 2019)
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Where a plaintiff seeks damages based on alleged illegal actions of a municipal official, there is no authority to award damages against the municipality when the jury concludes that the official committed no wrong. Plaintiff filed suit against the city and the mayor under 42 U.S.C. 1983, alleging that defendants discriminated against him based on race in violation of 42 U.S.C. 1981. The jury returned a verdict in favor of the mayor but against the city.
The Eighth Circuit reversed and held that, because there was no race discrimination violation of section 1981, the city could not be held liable for damages under section 1983. In this case, plaintiff did not challenge the jury's finding that the mayor did not discriminate against him based on race and there was insufficient evidence that any other city official, or combination of the mayor or other municipal officers or employees, discriminated against plaintiff based on race.
Court Description: Colloton, Author, with Gruender and Erickson, Circuit Judges] Civil case - Civil rights. Where the jury found for the individual defendant - the City mayor - and against the City on plaintiff's claim that the mayor and the City terminated him on the basis of his race, the verdict against the City must be overturned as there is insufficient evidence that any city official, or a combination of the mayor and other municipal officials or employees, discriminated against plaintiff on the basis of his race; as there was no race discrimination in violation of Section 1982, the City cannot be held liable for damages under Section 1983.
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