Central Specialties, Inc. v. Large, No. 20-3027 (8th Cir. 2021)
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CSI, which won a contract to perform road work on state highways across three Minnesota counties, filed a 42 U.S.C. 1983 action against Mahnomen County and its Engineer, Jonathan Large, after Large stopped two of CSI's trucks for exceeding the posted weight limit on the road on which they were traveling.
The Eighth Circuit affirmed the district court's grant of summary judgment on the constitutional claims, concluding that, under the unique circumstances of this case, it was not clearly established that Large, a county engineer tasked with oversight of all county roads, could not prevent trucks that he had reason to believe were operating above the posted weight limit from passing over and damaging the roadway or could not call law enforcement to investigate compliance with the new, reduced weight restrictions. The court also concluded that it was not clearly established at the time that defendants could not change the weight restrictions in response to CSI's stated intentions to use the road despite the fact it had not been designated as a haul road or that the engineer could not seek law enforcement's assistance in investigating the trucks' weights. Furthermore, because CSI's complaint failed to allege any policy or custom of the county related to the engineer's conduct, claims against the county failed. Finally, the court concluded that the district court properly granted summary judgment in favor of defendants on CSI's state law claim for tortious interference with contract, and the engineer did not exercise the dominion and control over plaintiff's trucks required to support a trespass to chattel claim.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Grasz, Circuit Judge] Civil case - Civil rights. The district court did not err in granting the defendant County Engineer summary judgment based on qualified immunity on plaintiff's claim that he seized plaintiff's trucks in violation of the Fourth and Fourteenth Amendments as it was not clearly established at the time of the incident that a county engineer tasked with oversight of all county roads could not prevent trucks that he had reason to believe were operating above the posted weight limit from passing over and damaging the county roadway or could not call law enforcement officers to investigate compliance with new, reduced weight restrictions; nor was it clearly established that defendants could not change the weight restrictions in response to plaintiff's stated intentions to use the road despite the fact it had not been designated as a haul road or that the engineer could not seek law enforcement's assistance in investigating the trucks' weights; as plaintiff's complaint did not allege any policy or custom of the county related to the engineer's conduct, plaintiff's claim against the county must fail; because defendants were justified, as a matter of law, in changing weight restrictions and stopping plaintiffs' trucks, the district court properly granted summary judgment to defendants on plaintiff's state law claim for tortious interference with contract; the engineer did not exercise the dominion and control over plaintiff's trucks to required to support a trespass to chattel claim under Minnesota law. Judge Grasz, concurring in part, and dissenting in part.
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