Legal Gaffe Prolongs Case of Former St. Louis Detainee Held Eight Months After Dismissal of Charges
by Matthew Thomas Clarke
On June 17, 2024, the U.S. Court of Appeals for the Eighth Circuit decided a civil rights complaint brought by former St. Louis jail detainee Michael Jones, who was held eight months longer after his charges were dismissed. Despite the outrageous government conduct in his case, the Court found it did not violate his rights under the Fourth Amendment, which was the basis of Jones’ only surviving federal claim. He had voluntarily dismissed claims appropriately grounded in the Fifth and Fourteenth Amendments—without prejudice, luckily. Jones was eventually able to get his case back on track, but the error serves to instruct other detainees making similar claims.
Jones was arrested on one felony charge and one misdemeanor charge, and he was held at St. Louis Medium Security Institution (MSI) pending trial. About three months later, when the court dismissed the charges against Jones in November 2013, no one informed him. In fact, no one told him even when he was finally released from MSI eight months after that.
Almost six years later, in August 2019, Jones finally found out that the charges had been dismissed and he had been held months longer than needed. Understandably outraged, he obtained assistance from St. Louis attorneys Mark R. Niemeyer, Elad J. Gross and Patrick Anton Hamacher of Niemeyer and Grebel, who filed a federal civil rights action on his behalf under 42 U.S.C. § 1983 in February 2021. The complaint asserted claims against the City of St. Louis and various employees, including claims that the prolonged detention violated Jones’ rights under the Fourth, Fifth and Fourteenth Amendments to the U.S. Constitution.
Defendants filed a motion to dismiss based on qualified immunity (QI). Before the district court ruled on that motion, however, Jones moved in November 2022 to dismiss his Fifth and Fourteenth Amendment due process claims, calling them “duplicative”—apparently of his Fourth Amendment claim—as the Eighth Circuit later recalled. The district court subsequently denied Defendants’ motion to dismiss, and they filed an interlocutory appeal, arguing for dismissal of the Fourth Amendment claim that the prolonged detention violated the prohibition against unreasonable seizure, as well as related municipal liability claims.
Since Jones had volunteered his partial dismissal, the Eighth Circuit said, “there [were] no federal due process claims … on appeal.” However, the Court held, an excessive detention claim cannot be brought under the Fourth Amendment if there is no question that the arrest—the “seizure”—was constitutional, citing Goldberg v. Hennepin County, 417 F.3d 808 (8th Cir. 2005). Instead, the claim should have been framed as a violation of due process under the Fifth and Fourteenth Amendments, the Court said. “As succinctly stated by Judge Richard Proser of the Seventh Circuit, ‘There is a difference between seizing a person and not letting him go,’” the Court said, quoting Llovet v. City of Chicago, 761 F.3d 759 (7th Cir. 2014.). The Court also held that Jones had failed to allege that the individual defendants were personally involved in his prolonged detention, amid a general paucity of alleged facts.
Because he had dismissed his valid claims and his only remaining federal claim for unreasonable seizure was untenable, Defendants should have been granted QI, the Court held—meaning the municipal liability claims must also be dismissed, as per Muir v. Decatur County, 917 F.3d 1050 (8th Cir. 2019). Thus, the Court reversed denial of QI and remanded the case for dismissal of the federal claims, plus a determination whether to proceed with pendent state claims—which the district court could decline to exercise pendent jurisdiction over, the Court noted. See: Jones v. City of St. Louis, 104 F.4th 1043 (8th Cir. 2024).
The case then returned to the district court, where Jones was granted leave and filed a Second Amended Complaint on September 4, 2024—nearly two years after abandoning the valid constitutional claims that it restated. The case remains pending, and PLN will update developments as they are available. See: Jones v. City of St. Louis, USDC (W.D. Mo.), Case No. 4:21-cv-00137.
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Related legal cases
Jones v. City of St. Louis
| Year | 2025 |
|---|---|
| Cite | USDC (W.D. Mo.), Case No. 4:21-cv-00137 |
| Level | District Court |
| Conclusion | Bench Verdict |
Jones v. City of St. Louis
| Year | 2024 |
|---|---|
| Cite | 104 F.4th 1043 (8th Cir. 2024) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Appeals Court Edition | F.4th |