Missouri Court of Appeals Affirms Summary Judgment in Favor of Municipality in Class Action Lawsuit
On September 29, 2020, the Eastern District of the Missouri Court of Appeals affirmed a circuit court’s order granting summary judgment in favor of a municipality represented by Behr, McCarter & Potter.
The case involved application of Missouri’s Macks Creek Law, which required that local governments submit annual financial statements to the state auditor. At that time, the Macks Creek Law contained a provision that any local government that failed to submit a timely financial report would “suffer an immediate loss of jurisdiction of the municipal court . . . on all traffic-related charges” until it satisfied the reporting requirements. The plaintiffs brought a class action lawsuit against the municipality under 42 U.S.C. § 1983, alleging that the municipality illegally operated a court without jurisdiction over traffic matters and that the traffic charges and convictions against them violated their constitutional rights. The circuit court granted summary judgment in favor of the defendant municipality, finding that there was no illegal custom or policy as required for liability under § 1983.
In an unpublished memorandum opinion, the court of appeals affirmed summary judgment in favor of the municipality. The court determined that the municipality had no unconstitutional custom or policy of operating its court without jurisdiction, and that the causal link between the late filing of the financial statements and the alleged damages was too attenuated to result in municipal liability under § 1983.