Mary Meier v. City of St. Louis, Missouri, No. 22-2332 (8th Cir. 2023)
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Plaintiff filed a Section 1983 lawsuit against the City of St. Louis and Doc’s Towing, Inc., alleging that Defendants violated her Fourth and Fourteenth Amendment rights when they detained her truck pursuant to a “wanted” report. On the first appeal of this case the Eighth Circuit found that the evidence was sufficient for Plaintiff’s claims to survive summary judgment. Plaintiff then settled with Doc’s Towing, and her case against the City proceeded to trial. The district court granted judgment as a matter of law in favor of the City on Plaintiff’s unreasonable seizure claim, and the jury returned a verdict for Plaintiff on her due process claim and awarded her compensatory damages. The district court denied the City’s post-trial motion for judgment as a matter of law but partially granted its motion to reduce the damages award. Both the City and Plaintiff appealed.
The Eighth Circuit affirmed. The court explained that as to Plaintiff’s assertion on cross-appeal that the district court erred by granting the City judgment as a matter of law on her unreasonable seizure claim, the court declined to reverse that ruling. The court explained that her due process claims and unreasonable seizure claim sought compensation for the same injury, and she concedes that she would not be entitled to additional compensatory damages beyond those that were already awarded by the jury. Accordingly, the court declined to remand because Plaintiff failed to articulate what relief she could obtain beyond what she has already achieved by way of the jury verdict.
Court Description: [Kelly, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. Plaintiff brought this action after St. Louis police and a tow company detained her truck pursuant to a "wanted" report. For the court's prior opinion in the matter, see Meier v. City of St. Louis, 934 F.3d 824 (8th Cir. 2019). A reasonable jury could have found that plaintiff presented sufficient evidence of a close nexus between the City and the due process violation she alleged because the unlawful detention of the vehicle by the tow company was fairly attributable to the City; the plaintiff's judgment on her due process claim is affirmed; the court declines to reverse the City's judgment as a matter of law on plaintiff's unreasonable seizure claim; the district court did not abuse its discretion in granting, only in part, the City's motion for an offset for the sums the tow company paid in settling plaintiff's claim.
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