McKay v. City of St. Louis, No. 19-1912 (8th Cir. 2020)
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In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released.
The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Civil case - Civil rights. The district court correctly granted summary judgment to the police defendants on plaintiff's Section 1983 Brady claim as there was no evidence that evidence related to his criminal prosecution was intentionally destroyed or suppressed; the record did not create a genuine dispute of material fact on plaintiff's claim the police defendants fabricated evidence, and the district court did not err in granting the defendants summary judgment; the record contradicts plaintiff's claim that the police defendants failed to investigate another man as a suspect in the robbery, and the district court did not err in granting defendants summary judgment on plaintiff's claim they violated his constitutional rights by recklessly or intentionally failing to investigate the man; because plaintiff has failed to prove deprivation of a constitutional right, his conspiracy claim necessarily fails; because the district court correctly found the police defendants did not violate plaintiff's constitutional rights, his Monell claims against the members of the Police Board in their official capacity and against the Board fails.
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