Langford v. City of St. Louis, No. 20-1488 (8th Cir. 2021)
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Plaintiff filed suit challenging the constitutionality of a traffic ordinance in St. Louis. Plaintiff's claims arose from her attendance at an event called the Women's March in 2017 where she was arrested for failing to move to the sidewalk. An officer arrested her for violating section 17.16.275 of the Revised Code of St. Louis, which prohibits obstructing traffic. After the charges were dismissed, plaintiff filed suit under 42 U.S.C. 1983, challenging the constitutionality of the ordinance under the First and Fourteenth Amendments.
The Eighth Circuit reversed the district court's grant of plaintiff's motion for partial summary judgment. The court concluded that the St. Louis ordinance does not forbid all expressive activities on streets and sidewalks. Instead, it merely forbids a person to position herself in a way that obstructs the reasonable flow of traffic. Therefore, plaintiff has not established that the ordinance unduly restricts free speech in light of the City's legitimate interest in regulating traffic. The court also concluded that the ordinance is not void for vagueness and thus is not unconstitutional on its face. The court further concluded that the ordinance is not unconstitutional as applied to plaintiff where the record does not support a conclusion that police invidiously discriminated against plaintiff based on her speech by selectively enforcing the traffic ordinance. The court remanded with directions to enter judgment for the City.
Court Description: [Colloton, Author, with Wollman and Shepherd, Circuit Judges] Civil case - Civil rights. The district court erred in determining that Section 17.16.275 of the Revised Code of St. Louis, which prohibits obstructing traffic, was an unconstitutional restriction on speech, was void for vagueness and was unconstitutionally applied to plaintiff when she was arrested for failure to move out of the street and onto a public sidewalk during the January 2017 Women's March.
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