Watson v. Boyd, No. 20-1743 (8th Cir. 2021)
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Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the City of Ferguson, alleging violations of his First, Fourth, and Fourteenth Amendment rights. Plaintiff's claims stemmed from nine citations he received from the officer at a park. The district court found that the officer was not entitled to qualified immunity and thus denied defendants' joint motion for summary judgment.
After determining that it had jurisdiction, the Eighth Circuit vacated the district court's order denying defendants' joint motion for summary judgment and remanded so that the district court may further consider the officer's asserted entitlement to qualified immunity. In this case, when discussing plaintiff's Fourth Amendment seizure claim, the district court commenced its analysis by citing case law that outlined the general legal standards for probable cause and reasonable suspicion, but it largely failed to apply this case law, or more analogous cases, to plaintiff's version of the facts. Furthermore, the district court failed to conduct the materiality inquiry by framing legal questions as factual ones; the court was unable to discern whether the district court applied the clearly established prong at all, much less conducted a "thorough determination;" the district court defined the relevant law at too high a level of generality to conduct a proper clearly established analysis; and the district court's excessive force analysis fails to identify a specific right or factually analogous cases. Finally, the court dismissed the City's appeal for lack of jurisdiction.
Court Description: [Shepherd, Author, with Erickson and Kobes, Circuit Judges] Civil case - Civil rights. In action alleging the police defendant and the City of Ferguson, Missouri violated plaintiff's First, Fourth, and Fourteenth Amendment rights by seizing him, searching his car, pointing a gun at him and issuing him tickets for nine different violations, the district court erred in denying defendants' motion for summary judgment based on qualified immunity, and the matter must be remanded so that the district court may further consider the police officer's asserted entitlement to qualified immunity; the district court failed to adequately address whether the factual disputed were material; nor can this court determine whether the district court thoroughly analyzed and determined the question of whether a clearly established right was involved; additionally, the court defined the relevant law at too high a level of generality to conduct a proper "clearly established" analysis; finally, the district court's excessive force analysis failed to identify a specific right or factually analogous case; because of the district court's incomplete analysis on both the constitutional violation and the clearly established prongs, the court can neither affirm nor reverse the denial of qualified immunity, and the matter must be remanded for further consideration; the City's appeal is dismissed for lack of jurisdiction as the decision to remand the claims against the officer does not resolved plaintiff's Monell claim against the City.
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