Williams v. City of Sherwood, No. 18-2982 (8th Cir. 2020)
Annotate this Case
Plaintiff filed suit against the city under 42 U.S.C. 1983, alleging that it had jailed her without inquiring into whether she had the means to pay the fines imposed and without appointing counsel for her. The district court dismissed plaintiff's claims on the ground that a judgment in her favor would necessarily imply the invalidity of her conviction or sentence under Heck v. Humphrey, 512 U.S. 477, 487 (1994).
The Eighth Circuit affirmed the dismissal of plaintiff's claims, although on different grounds. The court held that the judicial decisions of a duly elected judge are not the kind of decisions that expose municipalities to section 1983 liability. Furthermore, neither the city council nor the mayor has the power to set judicial policy for Arkansas district court judges or the power to ratify their decisions even if the city's policymakers knew of the judge's conduct and approved of it. In this case, the court held that the district court did not err by dismissing plaintiff's claims about the district court's failure to inquire into her indigency and failure to appoint counsel, along with her related, derivative claims about the practices in the Sherwood District Court.
Court Description: [Arnold, Author, with Erickson and Kobes, Circuit Judges] Civil case - Civil rights. The judicial decisions of a duly elected judge are not the kind of decisions that expose municipalities to Section 1983 liability; neither the city council nor the mayor has the power to set judicial policy for Arkansas district court judges or the power to ratify their decisions even if the city's policymakers knew of the judge's conduct and approved of it; the district court did not err in dismissing plaintiff's claims about the court's failure to inquire into her indigency and failure to appoint counsel, along with her derivative claims about the practices of the Sherwood District Court.
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.