Stockley v. Joyce, No. 19-1573 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants under 42 U.S.C. 1983 and state law, stemming from plaintiff's acquittal of a first degree murder charge. Plaintiff was a St. Louis Metropolitan Police Department (SLMPD) officer at the time he shot and killed a fleeing suspect.
The court held that the district court did not err in dismissing plaintiff's claims against the city prosecutor based on absolute immunity; the prosecutor's decision that there was sufficient evidence to end the investigation, even after only one day, and charge plaintiff with first degree murder clearly falls within the prosecutorial function of initiating judicial proceedings; and, even if the prosecutor's termination of the investigation and initial decision declining to prosecute plaintiff could be construed as indicating that she had an improper motive, allegations of unethical conduct and improper motive in the performance of prosecutorial functions did not defeat the protection of absolute immunity. The court also held that plaintiff failed to state a substantive due process claim against the prosecutor based on her public statements where the conduct did not rise to the level of conscience-shocking. Finally, plaintiff failed to state a defamation claim against the prosecutor.
The court also held that the district court did not err in dismissing the section 1983 and malicious prosecution claims against a sergeant in the police department's Internal Affairs Division in his individual capacity. Furthermore, the district court properly dismissed the Monell claim against the city where the prosecutor's decision to terminate the investigation and charge plaintiff was an individual charging decision based upon a particular set of facts supported by arguable probable cause.
Court Description: [Shepherd, Author, with Gruender and Arnold, Circuit Judges] Civil case - Civil rights. In this Section 1983 action against the city prosecutor, a police force investigator and the City by a former St. Louis police officer who was acquitted of murdering a fleeing suspect in a drug investigation, the district court did not err in determining that the prosecutor was entitled to absolute immunity for her decision to charge plaintiff with the offense; the prosecutor's decision that there was sufficient evidence to end the police force's internal investigation and charge plaintiff clearly falls within the prosecutorial function of initiating judicial proceedings; while the prosecutor's actions in making comments to the press that she had new evidence regarding plaintiff's guilt were not protected by absolute immunity, the conduct did not remotely rise to the conscience-shocking level and was not a substantive due process violation; with respect to plaintiff's claim that the prosecutor defamed plaintiff under Missouri law, the first part of her comments - that she had new evidence - was not defamatory as a matter of law; with respect to the second part of her statement - that the evidence proved plaintiff was guilty of first-degree murder - he could not show that the statements damaged his reputation where, as here, he was charged, arrested and tried for first-degree murder; with respect to plaintiff's claims that the internal affairs investigator violated his due process rights by including false information and omitting material information in the probable cause affidavit because an accurate affidavit would not have resulted in a judicial finding of probable cause, the argument is foreclosed by the Supreme Court's decision in Manuel v. City of Joliet, 137 S.Ct. 911 (2017) that such a claim is a Fourth Amendment claim and not a due process clause claim; further, even with the additional information and without the challenged information, it would not be impossible for the issuing judicial officer to find probable cause; with respect to plaintiff's claim that the officer's actions amounted to malicious prosecution, plaintiff failed to state a claim under Missouri law; with respect to plaintiff's Monell claim against the City, the prosecutor's decision to terminate the internal affairs investigation and initiate a criminal charge was an individual charging decision based upon a particular set of facts supported by arguable probable cause, and the conduct did not constitute municipal policy.
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