Bruce v. City of St. Louis, Missouri

CourtDistrict Court, E.D. Missouri
DecidedMarch 13, 2024
Docket4:23-cv-00236
StatusUnknown

This text of Bruce v. City of St. Louis, Missouri (Bruce v. City of St. Louis, Missouri) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bruce v. City of St. Louis, Missouri, (E.D. Mo. 2024).

Opinion

UENAISTTEEDR SNT DAITSETSR DICISTT ORFI CMTI SCSOOUURRTI EASTERN DIVISION DOUGLAS BRUCE, ) ) Plaintiff, ) ) v. ) Case No. 4:23CV236 JAR ) CITY OF ST. LOUIS, MISSOURI, ) ) Defendant. ) MEMORANDUM AND ORDER This matter is before the Court on Defendant’s Motion to Dismiss. ECF No. 10. Plaintiff filed his response in opposition. The Motion is fully briefed and ready for disposition. For the reasons set forth below, the Court finds that Plaintiff’s Complaint is insufficient as plead and will allow him fourteen days to file an amended complaint. Background and Facts On February 27, 2023, Plaintiff Douglas Bruce, a Colorado resident, filed this action against Defendant, alleging municipal liability and excessive fines related to the demolition of two single-family homes that he owns in the City of St. Louis, Missouri. Plaintiff’s Complaint [ECF No. 1] states, in pertinent part,1 that he owns two single- family homes, located at 4928 St. Louis Avenue and 418 Christian Avenue (the “Properties”), that Defendant demolished without any proper notice. Plaintiff alleges that he did not receive any notice from Defendant regarding any maintenance issues or other possible bases for the demolition of the Properties nor did he receive notice of any fines connected to the Properties. Plaintiff believes that Defendant demolished the Properties and issued fines, penalties, tax liens, and other charges against the Properties without proper notice to him because it maintains certain 1 Unless otherwise noted, all facts in this section are alleged in Plaintiff’s Complaint and accepted as true for policies, practices, customs, and ordinances permitting such actions. Because Plaintiff was not given any advance notice, he did not have an opportunity to contest the demolitions. Accordingly, Plaintiff filed this action, alleging the following four counts in his Complaint: three counts of municipal liability, specifically the deprivation of property (Count One) and violation of procedural due process (Count Two) under the Fifth and Fourteenth Amendments, and the violation of substantive due process (Count Three); and excessive fines in violation of the Eighth and Fourteenth Amendments (Count Four). Plaintiff seeks a declaratory judgment, monetary damages, attorneys’ fees and costs. Defendant filed the instant motion, pursuant to Federal Rules of Civil Procedure 12(b)(6), requesting the Court to dismiss Plaintiff’s Complaint for failure to state a claim on all counts.

Legal Standard Federal Rule of Civil Procedure 8(a) requires that a pleading contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). If a pleading fails to state a claim upon which relief can be granted, an opposing party may move to dismiss it. See Fed. R. Civ. P. 12(b)(6). The purpose of a Rule 12(b)(6) motion to dismiss for failure to state a claim is to test the legal sufficiency of a complaint to eliminate those actions “which are fatally flawed in their legal premises and deigned to fail, thereby sparing the litigants the burden of unnecessary pretrial and trial activity.” Young v. City of St. Charles, 244 F.3d 623, 627 (8th Cir. 2001). This court “accepts as true the complaint's factual allegations and grants all

reasonable inferences to the non-moving party.” Park Irmat Drug Corp. v. Express Scripts Holding Co., 911 F.3d 505, 512 (8th Cir. 2018) (citations omitted). To survive a motion to dismiss, a complaint must contain “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, Plaintiff's obligation to provide the grounds of its entitlement to relief “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Id. at 555. A claim is facially plausible when “the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). However, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements,” will not pass muster. Iqbal, 556 U.S. at 678. Discussion Municipal Liability (Count One) Defendant argues that Plaintiff’s claim in Count One should be dismissed because he

fails to state a claim for municipal liability based on Defendant’s policies or customs. In Monell v. Dep’t of Soc. Servs., the United States Supreme Court held that local governing bodies, like Defendant, “can be sued directly under § 1983 for monetary, declaratory, or injunctive relief where . . . the action that is alleged to be unconstitutional implements or executes a policy statement, ordinance, regulation, or decision officially adopted and promulgated by that body’s officers.” 436 U.S. 658, 690–91 (1978). Additionally, local governments may be liable for constitutional violations “pursuant to governmental ‘custom’ even though such custom has not received formal approval through the body’s official decisionmaking channels.” Id. at 691.

“A ‘policy’ is an official policy, a deliberate choice of a guiding principle or procedure made by the municipal official who has final authority regarding such matters.” Bechtel v. City of Belton, 250 F.3d 1157, 1160 (8th Cir. 2001) (alteration omitted) (quoting Mettler v. Whitledge, 165 F.3d 1197, 1204 (8th Cir. 1999)). An actionable custom requires Plaintiff to establish: (1) The existence of a continuing, widespread, persistent pattern of unconstitutional misconduct by the governmental entity’s employees; (2) D eliberate indifference to or tacit authorization of such conduct by the governmental entity’s policymaking official after notice to the officials of that misconduct; and

(3) The plaintiff’s injury by acts pursuant to the governmental entity’s custom, i.e., proof that the custom was the moving force behind the constitutional violation.

Jane Doe A v. Special Sch. Dist. of St. Louis Cnty., 901 F.2d 642, 646 (8th Cir. 1990). Plaintiff's Complaint is composed primarily of conclusory allegations that he was deprived of his constitutional rights by Defendant because of its policies, practices, customs, and ordinances by issuing excessive fines against the Properties and demolishing the Properties without proper notice to him and without the ability to contest them. Although Plaintiff fails to specifically identify the existence of an unconstitutional policy or custom, he is correct that this is not fatal to his claim at this stage of the proceeding. The Court recognizes that when a complaint is filed, a plaintiff “may not be privy to the facts necessary to accurately describe or identify any policies or customs which may have caused the deprivation of a constitutional right.” Doe v. Sch. Dist.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Austin v. United States
509 U.S. 602 (Supreme Court, 1993)
United States v. Bajakajian
524 U.S. 321 (Supreme Court, 1998)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mills v. City of Grand Forks
614 F.3d 495 (Eighth Circuit, 2010)
Randal L. Bechtel v. City of Belton, Missouri
250 F.3d 1157 (Eighth Circuit, 2001)
Park Irmat Drug Corp. v. Express Scripts Holding Co.
911 F.3d 505 (Eighth Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Bruce v. City of St. Louis, Missouri, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bruce-v-city-of-st-louis-missouri-moed-2024.