Austell v. City of Pagedale

District Court, E.D. Missouri·Decided December 21, 2023·No. 4:22-cv-01006·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JANET L. AUSTELL, ) ) Plaintiff, ) ) v. ) No. 4:22-CV-01006-AGF ) CITY OF PAGEDALE, et al., ) ) ) Defendants. )

MEMORANDUM AND ORDER This matter is before the Court on Pro Se Plaintiff Janet Austell’s motion for leave to file an amended complaint. Doc. No. 38. Defendant City of Pagedale (the “City”) has opposed Plaintiff’s motion on the basis that Plaintiff has failed to remedy the issues with her complaint and amendment is futile because the proposed amended complaint fails to state a claim. For the reasons set forth below, Plaintiff’s motion will be granted in part and denied in part. BACKGROUND

Prior Complaint Plaintiff initially filed a complaint on September 23, 2022, alleging violations under 42 U.S.C. §§ 1981, 1983, and 1988; conspiracy to violate civil rights under 42 U.S.C. § 1985; violations of the Equal Protection Clause of the Fourteenth Amendment; and asserting a claim for Declaratory Judgment. Doc. No. 1. Plaintiff alleged that the City of Pagedale, and a number of its employees—Eddie Simmons, Sam J. Alton, Officer Justin Cull, and Officer Brown—violated her civil rights and conspired to violate her civil rights by issuing a number of improper warnings and citations against her property located at 1539 Farris Avenue.1 In response, Defendants filed motions to dismiss the

complaint on the basis of res judicata, failure to state a claim under Fed. R. Civ. P. 12(b)(6), and failure to comply with Fed. R. Civ. P. 8(a)(2) and 8(d)(1). Doc. Nos. 20, 22. On July 31, 2023, the Court dismissed Plaintiff’s complaint. Doc. No. 37. Specifically, the Court found that Plaintiff’s allegations regarding the alleged incidents

that occurred in 2018 and 2019 were barred by res judicata because they were previously litigated in Austell v. City of Pagedale, et al., Case No. 4:19-cv-02596-SRC. Such claims were dismissed with prejudice. The Court further found that the claims against Eddie Simmons, Sam Alton, Officer Brown, and Officer Cull were redundant of the claims against the City because the individuals were only sued in their official capacities.

Additionally, the Court held that Plaintiff had failed to state a claim under (1) 42 U.S.C. § 1981 because she failed to allege her membership in a protected class and Defendants’ intent to discriminate on the basis of Plaintiff’s race; (2) 42 U.S.C. § 1983 because she failed to allege that there is a policy or custom adopted by the City regarding the issuance of meritless warnings/citations or that the ordinances themselves are unconstitutional; (3)

42 U.S.C. § 1985 because Plaintiff failed to allege any facts to suggest a “meeting of the minds” in her conspiracy claim; and (4) 42 U.S.C. § 1988 because pro se litigants are not

1 A detailed summary of Plaintiff’s allegations in her original complaint can be found in the Court’s previous order issued on July 31, 2023. Doc. No. 37. entitled to attorney fees and because all of her substantive claims had been dismissed. Lastly, the Court dismissed Plaintiff’s claim for declaratory judgment because a declaratory judgment cannot be a standalone cause of action and all of Plaintiff’s

substantive claims had been dismissed. The Court granted Plaintiff 30 days to seek leave to file an amended complaint. Amended Complaint On August 14, 2023, Plaintiff timely filed a motion for leave to amend her complaint. Doc. No. 38. Her motion included a proposed amended complaint in

compliance with Local Rule 4.07. Plaintiff’s amended complaint removes all claims prior to July 2021; the claims against Eddie Simmons, Sam Alton, Officer Justin Cull and Officer Brown; her claims under 42 U.S.C. § 1981, 1985, and 1988; and her claim for declaratory judgment. As such, the only claim in Plaintiff’s proposed amended complaint is a violation under 42 U.S.C. § 1983 against the City of Pagedale.

Defendant City of Pagedale opposes Plaintiff’s leave to amend on the basis that amendment is futile because Plaintiff’s proposed amended complaint fails to state a claim. Doc. No. 39. Plaintiff filed a response to Defendant’s opposition and included a new amended complaint, which Plaintiff claims satisfies the deficiencies cited in Defendant’s opposition. Doc. No. 40. In reply, Defendant argues that Plaintiff’s

amended complaint provided in Doc. No. 40 should not be considered by the Court because it was not filed within the 30 days prescribed by the Court in its previous order and is therefore untimely. Doc. No. 41. The Court has compared the amended complaint filed by Plaintiff on August 14, 2023 (Doc. No. 38-1) and the second amended complaint filed by Plaintiff on September 8, 2023 (Doc. No. 40). The second amended complaint clarifies Plaintiff’s claims and

includes the referenced exhibits, but it does not contain any new causes of action or significant new factual allegations. In light of these minor changes, and the liberal construction of complaints afforded to pro se plaintiffs,2 the Court will consider Plaintiff’s second proposed amended complaint for the purposes of this motion for leave to amend.

ARGUMENT OF PARTIES Defendant argues that Plaintiff’s motion for leave to amend her complaint should be denied as futile because Plaintiff has failed to state a claim upon which relief can be granted. Specifically, Defendant argues that Plaintiff has failed to allege facts demonstrating that the City’s issuance of “warnings” and “citations” was conducted

pursuant to an official City policy, custom, or deliberately indifferent failure to train or supervise. Defendant also argues that to the extent Plaintiff is alleging a Fourteenth Amendment procedural due process violation, she has failed to allege a constitutionally deficient procedure. Defendant further argues that Plaintiff’s proposed amended complaint fails to properly request relief because she fails to provide proof of actual

injury, establish her right to injunctive relief, and indicate that her alleged constitutional deprivation caused injury. Lastly, Defendant argues that Plaintiff has improperly sought

2 See Estelle v. Gamble, 429 U.S. 97,106 (1976) punitive damages against a municipality. In response, Plaintiff argues that she properly alleged a violation of her constitutional rights under § 1983 and that Defendant knowingly committed this violation

through its established and continued practice of improperly issuing false and meritless ordinance violations. Plaintiff argues that these violations deprived her of the use of her land and resulted in the improper removal of her personal property.

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