Michael Faulk v. Gerald Leyshock, No. 21-1116 (8th Cir. 2022)
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Plaintiff alleges he was unlawfully assaulted, pepper-sprayed, detained in an unlawful mass arrest, and ultimately incarcerated. He sued the City of St. Louis and multiple police officers for First, Fourth, and Fourteenth Amendment violations, conspiracy to deprive him of civil rights, and supplemental state law claims. One officer moved to dismiss the 1983 claims, arguing plaintiff’s amended complaint failed to state a claim and he is entitled to qualified immunity. The only allegations relating to the defendant’s involvement are that he was working on September 17 and took custody of the plaintiff’s bicycle lying in the street at the time of his arrest. These allegations do not establish a causal link between the plaintiff and the specific wrongs the defendants as a whole allegedly committed. Further, the defendant is entitled to qualified immunity because the amended complaint did not contain specific and plausible allegations linking the defendant to overt acts alleged as part of the conspiracy of all the defendants. The assertion that he agreed to participate in those acts does not state a plausible claim.
Finally, the circuit court held that the district court erred in denying the other defendants' motion to dismiss. The defendants are entitled to qualified immunity because the intracorporate conspiracy doctrine was not clearly established.
Court Description: [Loken, Author, with Shepherd and Stras, Circuit Judges] Civil Case - civil rights - qualified immunity. Journalist Michael Fault brought a civil rights action against City of St. Louis and multiple police department members related to their activities in quelling the protests and unrest following the acquittal an officer in the killing of Anthony Lamar Smith. As relevant to this appeal, Faulk brought First and Fourteenth Amendment claims against Officer James Woods and conspiracy claims against all defendants. The district court denied motions for qualified immunity to Woods and denied defendants' motion to dismiss the conspiracy claims. The district court erred in denying the motion to dismiss claims against Woods, as the amended complaint contained no facts showing Woods's personal involvement in the alleged First and Fourteenth Amendment claims, other than that he was working that day and took custody of Faulk's bicycle. Even after discovery in a related case, the amended complaint lacks a factual basis to infer personal involvement. As to the conspiracy claims, the amended complaint did not contain specific and plausible allegations linking Woods to overt acts alleged as part of the conspiracy of all the defendants and the allegation that he agreed to participate in those acts do not state a plausible claim; thus he entitled to qualified immunity. As for the conspiracy claims against the other defendants, who asserted the intracorporate conspiracy doctrine provided a defense, the district court erred in denying their motion to dismiss. The defendants are entitled to qualified immunity because the intracorporate conspiracy doctrine is not clearly established.
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