8th Circuit: Maplewood not immune to claims of constitutional violations

The 8th U.S. Circuit Court of Appeals ruled Friday that the City of Maplewood enjoys no sovereign immunity against claims that its handling of traffic and vehicle violations is unconstitutional.

Those claims had been filed in the Eastern District of Missouri in November 2016 by six motorists aided by ArchCity Defenders, a nonprofit that provides legal counsel to the poor and homeless.

In the complaint, the plaintiffs had asserted that if a motorist in Maplewood gets ticketed for violating traffic or vehicle laws and fails to pay the fine or appear in court, the city automatically issues an arrest warrant.

If subsequently arrested, the motorist must either pay a bond that’s set in advance, without regard to his or her ability to pay, or go to jail, possibly for days. The plaintiffs alleged that even if the motorist tries to avoid arrest by going voluntarily to municipal court or by paying the original fine, they must retain an attorney to argue a motion that the arrest warrant be vacated. If that motion is denied, the motorist will be jailed.

In essence, the plaintiffs claimed, Maplewood dangles the threat of imprisonment to coerce low-income motorists into paying a bond that they can’t afford. Such a system, they wrote, violates their due-process and equal-protection rights under the U.S. Constitution.

The City of Maplewood sought to have the complaint dismissed by claiming, among other things, immunity from suit. U.S. District Judge Catherine D. Perry denied the motion. Maplewood appealed, and on Friday, the Eighth Circuit affirmed.

According to the Eighth Circuit’s ruling, written by judges Steven Colloton, Morris Arnold and Bobby Shepherd, the City of Maplewood claimed immunity on two grounds. First, it argued that the real party in interest is not the municipality, but rather the municipal court, which is an arm of the state of Missouri and thus immune under the Eleventh Amendment to the U.S. Constitution.

The judges countered that the Eleventh Amendment doesn’t apply to political subdivisions, and that even if Maplewood’s court were indeed entirely responsible, that fact would equip the city with a defense on the merits, not immunity.

Secondly, the city had argued that the absolute immunity of Maplewood’s individual officials creates immunity for the city as an entity. The judges disagreed.

“Even if we accepted the City’s premise that its officials all enjoy personal immunity from suit, it hardly follows that they did not engage in any unlawful acts or that the City is thereby immune as well.”

Judges Colloton, Arnold and Shepherd admitted that the 8th Circuit had “not always been as clear as we could have in discussing the relationship between individual and municipal liability,” and that it had showed an “occasional use of overbroad language” in related decisions.

Yet their case law, they wrote, was clear in denying a municipality immunity and buttressed by the U.S. Supreme Court’s express desire to give “victims of municipal malfeasance” some remedy when faced with immune municipal officials.

In a statement released right after the ruling, the plaintiffs’ attorneys at ArchCity Defenders wrote: “Too many municipalities continue to spend time, energy, and resources trying to evade responsibility for their unlawful practices. It’s time to stop looking for ways out and start making whole the people they have victimized.”

Attorneys for the City of Maplewood at Brinker & Doyen in Clayton did not immediately respond to requests for comment.