Curtis v. Christian County, No. 19-1213 (8th Cir. 2020)
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The Sheriff's Office appealed the district court's denial of qualified immunity on First Amendment wrongful-discharge claims brought by former Deputy Sheriffs Timothy Bruce and Robert Curtis. Bruce and Curtis's complaints alleged that Cole, the newly elected sheriff, discharged them for political reasons in violation of their First Amendment rights.
The Eighth Circuit reversed the district court's denial of qualified immunity, holding that political loyalty is an appropriate requirement for the job of deputy sheriff under Missouri law because of the closeness and cooperation required between sheriffs and their deputies in fulfilling overlapping duties. In this case, Cole did not violate Bruce and Curtis's constitutional rights. Consequently, the county is also entitled to summary judgment on the claims against it. The court remanded for further proceedings.
Court Description: [Smith, Author, with Colloton and Stras, Circuit Judges] Civil case - Civil rights. In an action brought by two discharged deputy sheriffs alleging they were discharged for political reasons in violation of their First Amendment rights, the district court denied the Sheriff's motion for summary judgment based on qualified immunity. Held: political loyalty is an appropriate requirement for employment under Missouri law; under Missouri law, the deputies are the alter ego of the Sheriff and therefore hold policymaking positions for which political loyalty is necessary to effective job performance; as a result, the Sheriff did not violate the former deputies' constitutional rights by discharging them; because the Sheriff did not violate plaintiffs' rights, the County is also entitled to summary judgment on the claims against it; reversed and remanded.
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