Derek Laney v. City of St. Louis, Missouri, No. 21-3530 (8th Cir. 2023)
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Plaintiff argued with a police officer during a protest in downtown St. Louis. Defendant- Lieutenant saw the confrontation and, fearing for the other officer’s safety, pepper-sprayed him. Plaintiff alleged that the force used was both excessive and retaliatory the district court granted qualified immunity. Plaintiff brought excessive force and First Amendment retaliation claims against the Lieutenant and a municipal liability claim against the City of St. Louis.
The district court dismissed Plaintiff’s federal claims at summary judgment and declined to exercise supplemental jurisdiction over what remained. The Eighth Circuit affirmed. The court explained that Plaintiff’s arguments are just general complaints about the Lieutenant’s “true motivations, intentions, and testimonial fabrications.” None of these arguments make any difference because “evil intentions will not make a Fourth Amendment violation out of an objectively reasonable use of force.” Further, even viewing the facts in a light most favorable to Plaintiff, causation is missing. As Plaintiff acknowledged, the Lieutenant “was not even in the area” when he criticized the Bicycle Response Team. Nor did Plaintiff “have any interaction with him” during the mere seconds between the beginning of the incident and the use of pepper spray. Accordingly, the court’s conclusion that the Lieutenant did not violate Plaintiff’s First or Fourth Amendment rights also forecloses his constitutional claims against the City of St. Louis.
Court Description: [Stras, Author, with Colloton and Wollman, Circuit Judges] Civil case - Civil rights. Police officer's use of pepper spray against plaintiff during a civil disturbance was a reasonable response under the circumstances, and the district court did not err in granting the defendant officer's motion for summary judgment based on qualified immunity on plaintiff's Fourth Amendment claim; with respect to plaintiff's First Amendment claim that the officer sprayed him in retaliation for making complaints about the police officers' actions during the demonstration, the officer was unaware of plaintiff's comments and would have used the spray absent any retaliatory motive.
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