Sarich v. City of St. Louis, Missouri

CourtDistrict Court, E.D. Missouri
DecidedMarch 25, 2025
Docket4:23-cv-00943
StatusUnknown

This text of Sarich v. City of St. Louis, Missouri (Sarich 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
Sarich v. City of St. Louis, Missouri, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION MATTHEW SARICH, ) ) Plaintiff, ) v. ) Case No. 4:23-cv-00943-SEP ) THE CITY OF ST. LOUIS, MISSOURI, et al., ) ) Defendants. ) MEMORANDUM AND ORDER Before the Court is a Motion to Dismiss filed by Defendants City of St. Louis and Samuel Gilman seeking dismissal of Counts IV and V of Plaintiff’s Complaint. Doc. [15]. Plaintiff opposes the motion. Doc. [17]. The motion is fully briefed and ready for disposition. See Docs. [15]-[18]. For the reasons set forth below, the motion is granted. BACKGROUND1 Plaintiff was arrested on August 2, 2018, after an altercation with a friend in the City of St. Louis. Doc. [2] ¶¶ 9,11. Officer Lori Wozniak of the St. Louis Metropolitan Police Department arrived on the scene after Plaintiff was arrested. Id. ¶¶ 4, 12. Plaintiff and his friend were placed in the back of Wozniak’s police vehicle for transport to South Patrol Division. Id. ¶ 13. Wozniak complained to her superior officer, Sergeant Samuel Gilman, about lewd comments Plaintiff and his friend made about her. Id. ¶ 17. Wozniak commented that “she was going to stop hard at every stop sign along the way to the station,” commonly referred to as a “rough ride.” Id. ¶¶ 17, 18. Gilman responded that “he did not want to hear that type of talk and to take the [Plaintiff] to the South Patrol Division.” Id. ¶¶ 19, 101. Wozniak then stated, “I would like to take them up to 270 and Riverview and let them walk home.” Id. ¶¶ 20, 102. Gillman specifically told Wozniak not to do that. Id. ¶¶ 21, 103. Sgt. Gilman did not assign another officer to transport Plaintiff. Id. ¶ 30. Two officers followed Wozniak in a separate vehicle and noted that she traveled a confusing route, as there were more direct routes back to the South Patrol Station. Id. ¶ 23. During the transport, Wozniak accelerated after a stop sign and then came to a complete and

1 For purposes of this motion, the Court takes the factual allegations in the Complaint, Doc. [2], to be true. See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989) sudden stop in the middle of the street, nearly causing an accident with the officers behind her. Id. ¶ 24. Plaintiff’s head was thrown against the interior of the police cruiser during Wozniak’s sudden stop. Id. ¶ 25. Plaintiff suffered a laceration above his right eye and a fractured clavicle because of the impact. Id. ¶ 26. Wozniak was found guilty of Assault 4th Degree by a jury in the Circuit Court of the City of St. Louis as a result of the incident. Id. ¶ 28. Plaintiff filed suit in this Court pursuant to 42 U.S.C. § 1983, alleging violations of his constitutional rights. Doc. [2]. The Complaint asserts five claims: Counts I through III against Wozniak, Count IV against the City, and Count V against Gilman. Id. The City and Gilman move for dismissal of the claims against them under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted. Doc. [15]. Gilman also claims to be shielded from liability by qualified immunity. Id. LEGAL STANDARD Under Federal Rule of Civil Procedure 12(b)(6), a court may dismiss an action for failure to state a claim upon which relief may be granted. When considering a Rule 12(b)(6) motion, a court assumes a plaintiff’s well-pled factual allegations to be true and makes all reasonable inferences in the plaintiff’s favor. Glick v. W. Power Sports, Inc., 944 F.3d 714, 717 (8th Cir. 2019). But a court does not accept as true legal conclusions or “threadbare recitals of the elements of a cause of action supported by mere conclusory statements.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (cleaned up). To survive a Rule 12(b)(6) motion, a complaint must allege sufficient facts to “state a claim to relief that is plausible on its face.” Iqbal, 556 U.S. at 678 (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility 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. “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Id. (quoting Twombly, 550 U.S. at 555); see also Hamilton v. Palm, 621 F.3d 816, 817 (8th Cir. 2010). Rule 8 does not “unlock the doors of discovery for a plaintiff armed with nothing more than conclusions.” Iqbal, 556 U.S. at 678-79. When ruling on a motion to dismiss, a court “must liberally construe a complaint in favor of the plaintiff.” Huggins v. FedEx Ground Package Sys., Inc., 592 F.3d 853, 862 (8th Cir. 2010). But if a claim fails to allege one of the elements necessary to recovery on a legal theory, the Court must dismiss that claim for failure to state a claim upon which relief can be granted. Crest Constr. II, Inc. v. Doe, 660 F.3d 346, 355 (8th Cir. 2011). Determining if well-pled factual allegations “plausibly give rise to an entitlement to relief” is a “context-specific” task requiring the court to “draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679, 682. In determining the plausibility of a plaintiff’s claim, Iqbal and Twombly instruct the Court to consider whether “obvious alternative explanations” exist for the allegedly unconstitutional conduct. Iqbal, 556 U.S. at 682; Twombly, 550 U.S. at 567. The well-pled facts must establish more than a “mere possibility of misconduct.” Iqbal, 556 U.S. at 679. “Where a complaint pleads facts that are ‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of entitlement to relief.’” Id. at 678 (quoting Twombly, 550 U.S. at 557). DISCUSSION I. Count IV – Municipal liability claim against Defendant City In Count IV of the Complaint, Plaintiff brings a municipal liability claim against the City based on Wozniak’s alleged violation of Plaintiff’s constitutionally protected rights.2 Doc. [2] at 11-13. “[A] municipality cannot be held liable under § 1983 on a respondeat superior theory.” Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658, 691 (1978). Instead, a municipality may be liable only for a constitutional violation that “resulted from (1) an official municipal policy, (2) an unofficial custom, or (3) a deliberately indifferent failure to train or supervise.” Mick v. Raines, 883 F.3d 1075, 1079 (8th Cir. 2018). Plaintiff’s Monell claim is based on allegations of unofficial customs within SLMPD and a failure to train.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hamilton v. Palm
621 F.3d 816 (Eighth Circuit, 2010)
Crest Construction II, Inc. v. Doe
660 F.3d 346 (Eighth Circuit, 2011)
Mike Yang v. Paul Hardin
37 F.3d 282 (Seventh Circuit, 1994)
Brian Ulrich v. Pope County
715 F.3d 1054 (Eighth Circuit, 2013)
Johnson v. Douglas County Medical Department
725 F.3d 825 (Eighth Circuit, 2013)
Huggins v. FedEx Ground Package System, Inc.
592 F.3d 853 (Eighth Circuit, 2010)
Kerrie Mick v. Wes Raines
883 F.3d 1075 (Eighth Circuit, 2018)
Josh Brewington v. Ben Keener
902 F.3d 796 (Eighth Circuit, 2018)
Connick v. Thompson
179 L. Ed. 2d 417 (Supreme Court, 2011)
Putman v. Gerloff
639 F.2d 415 (Eighth Circuit, 1981)

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Bluebook (online)
Sarich v. City of St. Louis, Missouri, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sarich-v-city-of-st-louis-missouri-moed-2025.