Ridgell v. City of Pine Bluff

935 F.3d 633 (2019) United States Court of Appeals for the Eighth Circuit 2019-08-29

City appeals denial of judgment as a matter of law after jury exonerates mayor but awards damages against City under §1983 for §1981 discrimination. (result: claimant-lost)

Facts

  1. 4 Judicial intentional-race-discrimination requirement not no-evidence
    Ridgell sued the City and Hollingsworth under 42 U.S.C. § 1983, claiming that they had racially discriminated against him in violation of 42 U.S.C. § 1981. At trial, Ridgell presented evidence of alleged comparator employees. Steve Miller, the Caucasian head of the City's Finance Department, had been disciplined, but not terminated, for failing to comply with one of Hollingsworth's directives, for going to the gym while taking leave under the Family and Medical Leave Act, and for tardiness. Ridgell testified that Robert Tucker, a Caucasian male, regularly arrived late to work but had never been disciplined.
  2. 4 Judicial intentional-race-discrimination requirement not no-evidence
    Having reviewed the record, we conclude that there was insufficient evidence from which a reasonable jury could have concluded that Holcomb's vote against overriding the mayor's action was based on race. Holcomb voted to override Hollingsworth's first termination of Ridgell because he believed at the time that Ridgell "was in the right." He later met with the City's human resources director and Hollingsworth and learned about the problems with Ridgell's work performance and tardiness. Based on this information, he concluded that Ridgell's second termination was the right decision, and said he had no reason to believe that Hollingsworth's decision was motivated by race.
  3. 4 Judicial intentional-race-discrimination requirement not no-evidence
    There was no evidence to contradict Holcomb's testimony, and Ridgell presented no other evidence supporting an inference that Holcomb voted against reinstatement because of Ridgell's race.
  4. 4 Judicial intentional-race-discrimination requirement not no-evidence
    In sum, Ridgell does not challenge the jury's finding that Hollingsworth did not discriminate against Ridgell based on race. There is insufficient evidence that any other city official, or a combination of Hollingsworth and other municipal officials or employees, discriminated against Ridgell based on race.
  5. 7 Judicial section 1983 remedial route for state-law impairment not law
    The jury returned a verdict in favor of Hollingsworth but against the City on Ridgell's claims of race discrimination and awarded damages of $24,080.
  6. 7 Judicial section 1983 remedial route for state-law impairment not law
    A municipality can act only through its employees, so a plaintiff seeking damages against a municipality under § 1983, for race discrimination that violated § 1981, must show that a municipal official or employee racially discriminated against him. See Jett v. Dall. Indep. Sch. Dist. , 491 U.S. 701, 735-36, 109 S.Ct. 2702, 105 L.Ed.2d 598 (1989) ; Russell v. Hennepin County , 420 F.3d 841, 846 (8th Cir. 2005).
  7. 7 Judicial section 1983 remedial route for state-law impairment not law
    The only municipal official or employee whom Ridgell cited to the jury as a wrongdoer was Hollingsworth.
  8. 7 Judicial section 1983 remedial route for state-law impairment not law
    Insofar as the case rests entirely on alleged wrongdoing by Hollingsworth, the City is entitled to judgment. The jury's finding that Hollingsworth did not racially discriminate against Ridgell means that the City cannot be held liable based on discrimination by Hollingsworth.
  9. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    A municipality can act only through its employees, so a plaintiff seeking damages against a municipality under § 1983, for race discrimination that violated § 1981, must show that a municipal official or employee racially discriminated against him.
  10. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    The only municipal official or employee whom Ridgell cited to the jury as a wrongdoer was Hollingsworth.
  11. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    He later met with the City's human resources director and Hollingsworth and learned about the problems with Ridgell's work performance and tardiness.
  12. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    There was no evidence to contradict Holcomb's testimony, and Ridgell presented no other evidence supporting an inference that Holcomb voted against reinstatement because of Ridgell's race.
  13. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    There is insufficient evidence that any other city official, or a combination of Hollingsworth and other municipal officials or employees, discriminated against Ridgell based on race.
  14. 3 Deprivation of a right, privilege, or immunity secured by the Constitution and laws not no-evidence
    Because there was no race discrimination in violation of § 1981, the City cannot be held liable for damages under § 1983.