L.G. v. Edwards, No. 20-2161 (8th Cir. 2021)
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After police officers interrogated L.G. at her high school, she filed suit under 42 U.S.C. 1983 alleging that the school resource officer had unconstitutionally seized her by escorting her to the office for questioning. Once L.G. was in the office, defendant left her alone with the officers and closed the door.
The Eighth Circuit reversed the district court's order rejecting defendant's request for qualified immunity and remanded with directions to dismiss the section 1983 claim against defendants. The court respectfully disagreed with the district court that it was clearly established that the school setting makes no difference for Fourth Amendment purposes when the seizure occurs at the behest of police. In this case, defendant's involvement in the alleged seizure was minimal and ministerial. Furthermore, the incident occurred in a public school setting where it would not necessarily be clear at what point a student has been unreasonably seized for constitutional purposes. Therefore, the court did not think existing circuit precedent, such as Stoner v. Watlingten, 735 F.3d 799, 804 (8th Cir. 2013), and Cason v. Cook, 810 F.2d 188 (8th Cir. 1987), would have alerted every reasonable officer in defendant's position that she was violating L.G.'s constitutional rights. The court also concluded that L.G. has not successfully demonstrated a robust consensus of persuasive authority that created a clearly established right, and this is not the rare case where a general constitutional rule applies with "obvious clarity."
Court Description: [Arnold, Author, with Smith, Chief Judge, and Stras, Circuit Judge] Civil case - Civil rights. Plaintiff, a minor high school student, who defendant, the school resource officer, escorted to an office for questioning by police officers, alleged defendant violated her civil rights by seizing her without probable cause; the district court denied defendant's motion for summary judgment based on qualified immunity and defendant appeals. Held: plaintiff failed to establish that defendant's conduct violated a clearly established constitutional or statutory right; two facts distinguish this case from those where the court has found a violation; first, the defendant's involvement in the alleged seizure was minimal and ministerial and, second, the incident occurred in a public school setting where it would not necessarily be clear at what point a student has been unreasonably seized for constitutional purposes; given these factors, existing circuit precedents would not have alerted a reasonable officer in defendant's position that she was violating plaintiff's constitutional rights by escorting her to a room containing two police officers and closing the door; nor was there a robust consensus of persuasive authority that created a clearly established right; nor is the kind of case where a general constitutional right applies with obvious clarity; reversed and remanded with directions to dismiss plaintiff's Section 1983 claims against defendant.
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