Hamilton v. City of Hayti, No. 18-3450 (8th Cir. 2020)
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Plaintiff filed suit against the city and others, seeking damages and injunctive and declaratory relief under 42 U.S.C. 1983, alleging unlawful arrest, detention, and prosecution, and the setting of an excessive cash-only bond that plaintiff was unable to pay due to indigency.
The Eighth Circuit affirmed the district court's dismissal of the section 1983 claims and held that the municipal judge was entitled to absolute judicial immunity from plaintiff's arrest and detention damage claims based on an invalid warrant issued by the court clerk; the judge's practice of setting a bond schedule conditioning the pretrial release of persons accused of municipal ordinance violations was a judicial act within his jurisdiction to which judicial immunity attaches; and the district court correctly concluded that the clerk was entitled to quasi-judicial immunity. Even if the court considered the judge's judicial bond practice to be part of municipal custom or usage, the court would still affirm the dismissal of the claim because there was no evidence of deliberate indifference to plaintiff's rights as an indigent arrestee. Finally, the court held that there was insufficient evidence for a reasonable jury to find a meeting of the minds between defendants on the conspiracy claim.
Court Description: [Loken, Author, with Colloton and Kobes, Circuit Judges] Civil case - Civil rights. In issuing the warrant for plaintiff's arrest, the court clerk exercised authority delegated by the municipal judge, who was acting within his jurisdiction; the judge was entitled to absolute immunity from plaintiff's arrest and detention damage claims based on an invalid warrant issued by the clerk; the judge's practice of setting a bond schedule conditioning pretrial release of persons accused of municipal ordinance violations was a judicial act within his jurisdiction to which judicial immunity applies; court clerk was entitled to quasi-judicial immunity for issuing an invalid arrest warrant that included a cash bond requirement; judge's bond practices were not attributable to the City; no error in granting summary judgment to defendants on plaintiff's Section 1983 conspiracy claim as plaintiff failed to establish a meeting of the minds.
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