Samantha LaCoe v. City of Sisseton, No. 22-3552 (8th Cir. 2023)Annotate this Case
Plaintiff was hired as a Law Enforcement Officer by the Sisseton, South Dakota, Police Department. Plaintiff and the City signed a Sisseton Police Department Employment Contract (the “Contract”) requiring Plaintiff to reimburse the City for the cost of her training if she left the Department before completing 36 months of employment. In January 2022, Defendant, the City’s Chief of Police, informed Plaintiff that the Police Commission had lost confidence in her, and Defendant asked Plaintiff to resign, which she did. Plaintiff filed this 42 U.S.C. Section 1983 action, asserting, along with other claims, that the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights. The district court granted Defendants’ motion. Plaintiff appealed only the dismissal of her due process claims.
The Eighth Circuit affirmed. The court agreed with the district court the Supreme Court of South Dakota would rule that the Contract did not change an at-will employment relationship. The court explained that for Plaintiff’s claim against the City to survive a motion to dismiss, her complaint must contain “enough facts to state a claim to relief that is plausible on its face.” The court agreed with the district court that the Complaint “failed to allege any unconstitutional policy or custom that enabled” Defendants to deprive Plaintiff of her alleged federal due process rights. Counsel for Plaintiff could only respond that the Complaint plausibly alleged the practice of violating the three-year term in the City’s employee reimbursement contracts. That practice was not alleged in the Complaint and, in any event, is nothing more than a “facially lawful municipal action.”
Court Description: [Loken, Author, with Colloton and Erickson, Circuit Judges] Civil case - Civil rights. Plaintiff, a former Sisseton Police Officer, alleged the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights by disciplining and constructively discharging her. The district court granted defendants' motion to dismiss all federal claims and declined to exercise supplemental jurisdiction over plaintiff's state law claim. Plaintiff appeals the dismissal of her due process claims, arguing the terms of her employment contract established a property interest in continued employment and that she was not an at-will employee under South Dakota law. Held: the Supreme Court of South Dakota would rule that the contract did not change an at-will employment relationship as the City expressly reserved its statutory at-will termination rights in Section 6 of the agreement; the complaint did not contain sufficient facts to support plaintiff's claim for municipal liability.