Bloodworth v. Kansas City Board of Police Commissioners, No. 22-3540 (8th Cir. 2023)
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The case before the United States Court of Appeals for the Eighth Circuit involved Allen Thomas Bloodworth, II, a business owner who operated two towing businesses in Kansas City. Bloodworth alleged that the Kansas City Board of Police Commissioners and fourteen officers of the Kansas City Police Department conspired to stop him from running his businesses and shut down his ability to conduct business in Kansas City. He brought 17 state and federal claims, including defamation, tortious interference with contract and business expectancy, intentional infliction of emotional distress, and negligent hiring, training, supervision, or retention. He also alleged Fourth Amendment violations for an unlawful warrant search and seizure of his residence and business, the shooting of his dog during the search, and the seizure of business records.
The district court granted summary judgment in favor of the defendants. On appeal, the Eighth Circuit affirmed the ruling. The appellate court concluded that Bloodworth failed to link the specific conduct of individual defendants to the alleged constitutional violations, and his claims were based on general assertions mostly. It also ruled that Bloodworth failed to establish that the defendants' conduct was extreme and outrageous to support his claim for intentional infliction of emotional distress. The court further found that Bloodworth failed to establish a constitutional violation resulting from the official policy, unlawful practice, custom, or failure to properly train, retain, supervise, or discipline the police officers. Therefore, there was no basis for municipal liability against the Kansas City Board of Police Commissioners.
Court Description: [Loken, Author, with Wollman and Benton, Circuit Judges] Civil case - Civil rights. In this action plaintiff alleges the Kansas City Board of Police Commissioners, acting through its board members and with the assistance of fourteen police officers, stopped him from operating his two businesses and kept him from conducting business with the City. The district court issued dismissal orders and then granted summary judgment to a group of police officers and officer Lemon; with respect to the group of officers they were entitled to official immunity for their acts in carrying out their responsibilities as police officers, and the district court properly dismissed plaintiff's state law claims against them. With respect to defendant Lemon, he was entitled to summary judgment on plaintiff's defamation claim concerning statements he made to plaintiff in a phone call, as he did not publish the statements himself and had no reason to believe they would be communicated to a third party; defendant Lemon was entitled to summary judgment on plaintiff's tortious interference claims as there was no evidence defendant took any part in the filing of forgery charges against plaintiff, and plaintiff had failed to identify any expectancies which were harmed; no error in granting summary judgment to Lemon on plaintiff's assault count based on statements made over the phone; no error in granting Lemon summary judgment on plaintiff's claim for intentional infliction of emotional distress as Lemon's conduct, while ill-considered, was not so extreme and outrageous as to qualify as intentional infliction under Missouri law; with respect to plaintiff's federal claims, the court summarily affirms every Section 1983 action against a defendant whose conduct was not specifically linked to that particular alleged violation; neither plaintiff's claim that defendants conducted a campaign against his business nor his claim of excessive force and unreasonable search and seizure established a constitutional violation; officers reasonably believed plaintiff's dog constituted an imminent danger to them when they shot the dog; claim defendants engaged in intentional Fourth Amendment violations by acting together to render plaintiff unable to conduct his business rejected; claim four defendant failed to properly supervise the officers must fail where the court finds no constitutional violation by the supervised officers; similarly, there is no Monell liability for the Board and its members.
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