Lawrence LaDeaux v. Woodbury County Jail, No. 21-1672 (8th Cir. 2021)

Annotate this Case

Court Description: [Per Curiam - Before Shepherd, Grasz, and Kobes, Circuit Judges] Civil case - Civil rights. The county jail was not an legal entity subject to suit; any official capacity claims against unnamed jail staff were claims against the County, and as plaintiff neither alleged nor presented evidence showing the alleged denial of medical care was due to any County policy or custom, the district court did not err in granting defendants summary judgment. [ September 02, 2021 ]

Download PDF
United States Court of Appeals For the Eighth Circuit ___________________________ No. 21-1672 ___________________________ Lawrence Conrad LaDeaux lllllllllllllllllllllPlaintiff - Appellant v. Woodbury County Jail; Unknown Woodbury County Jail Staff lllllllllllllllllllllDefendants - Appellees ____________ Appeal from United States District Court for the Northern District of Iowa - Western ____________ Submitted: August 30, 2021 Filed: September 3, 2021 [Unpublished] ____________ Before SHEPHERD, GRASZ, and KOBES, Circuit Judges. ____________ PER CURIAM. Lawrence LaDeaux appeals the district court’s1 adverse grant of summary judgment in his 42 U.S.C. § 1983 action. Upon de novo review, we affirm. See 1 The Honorable Linda R. Reade, United States District Judge for the Northern District of Iowa. Johnson v. Outboard Marine Corp., 172 F.3d 531, 535 (8th Cir. 1999) (standard of review; this court may affirm on any basis supported by record). We find that LaDeaux’s claim against the Woodbury County Jail failed, as the Jail was not a legal entity subject to suit. See Owens v. Scott Cnty. Jail, 328 F.3d 1026, 1027 (8th Cir. 2003) (per curiam) (affirming grant of summary judgment to jail, as county jails are not legal entities amenable to suit). As to the claims against the unnamed Jail staff, the complaint stated only official-capacity claims, and thus raised claims only against Woodbury County itself. See Johnson, 172 F.3d at 535 (in order to sue public official in his individual capacity, plaintiff must expressly and unambiguously state so in pleadings; official-capacity suit against public employee is merely suit against public employer). As LaDeaux neither alleged nor presented evidence showing that the alleged denial of medical care was due to any county policy or custom, we conclude that summary judgment was proper. See Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 694 (1978) (municipality may only be liable when constitutional violation at issue was committed pursuant to municipality’s policy or custom); Johnson, 172 F.3d at 536 (affirming grant of summary judgment where plaintiffs failed to allege facts or produce evidence showing that alleged constitutional violation was result of county policy or custom). The judgment is affirmed. See 8th Cir. R. 47B. ______________________________ -2-

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.