The Satanic Temple v. City of Belle Plaine, No. 21-3079 (8th Cir. 2023)
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The City of Belle Plaine, Minnesota, designated Veterans Memorial Park as a limited public forum and granted permits to two groups to place monuments there. Before the Satanic Temple could place its monument, the City closed the Park as a limited public forum and terminated both permits. The Satanic Temple sued the City. The district court dismissed its claims, except for promissory estoppel. When the Satanic Temple moved to amend its complaint, a Magistrate Judg2denied its motion. The Satanic Temple filed a second suit, reasserting the dismissed claims and adding new ones. The district court held that res judicata bars the second suit and granted summary judgment to the City on the promissory estoppel claim from the first suit.
The Eighth Circuit affirmed. The court explained that the Satanic Temple failed to plausibly allege that closing the Park as a limited public forum was unreasonable or viewpoint discriminatory. The court further explained that the Satanic Temple asserted that the City violated its free exercise rights. The court explained that although the Enacting and Recession Resolutions were facially neutral, facial neutrality is not a safe harbor if the City’s actions targeted the Satanic Temple’s religious conduct. However, the Satanic Temple failed to plausibly claim that its display was targeted. Moreover, the Satanic Temple has not plausibly alleged that it and the Veterans Club were similarly situated or that it was treated differently. The City gave a permit to both groups, had no control over the fact that the Veterans Club placed its statue first, and closed the Park as a limited public forum to everyone.
Court Description: [Kobes, Author, with Loken and Erickson, Circuit Judges] Civil case - Constitutional law. The City did not violate the Temple's free speech rights by closing Veterans Memorial Parak as a limited public forum and terminating permits to place statues in the park; with respect to the Temple's free exercise claims, the City's action did not target its display; the Temple did not state a claim under Article I, Section 16 of the Minnesota Constitution as the City's action did not burden the Temple's religious conduct or philosophy; the Temple's Equal Protection Clause claim fails as it has not plausibly alleged that it and the other group who sought a permit were similarly situated or that they were treated differently; with respect to the Temple's Religious Land Use and Institutionalized Persons Act claims, the Temple did not state a plausible claim; the permit and cover letter the Temple received permitted the City to rescind the permit and its action in doing so did not create a cause of action for promissory estoppel; the district court did not err in finding that certain claims raised in the Temple's first suit were barred by res judicata because the denial of leave to amend the complaint in that first suit constitutes res judicata on the merits of the claims; the magistrate judge had authority to decide the Temple's motion to amend its complaint and properly entered the order in the first case that constitutes the final judgment on the merits for res judicata purposes.
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