Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025

United States Court of Appeals for the Eighth Circuit · 2025-07-08

42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)

Original case on neochart.com

Case and law context

42 U.S.C. § 1983

Role: applied; posture: civil; firefighters named to acting positions sued the city under § 1983 claiming that the failure to promote them deprived them of property without due process or just compensation; district court granted summary judgment for defendants; CA8 affirmed; result: claimant-lost; claim:

Uncertainty

opinion: the IR text is a single paragraph (slip-opinion layout); the span starts at "ARNOLD, Circuit Judge." after the caption and ends at "Affirmed."; footnote 1 (the district judge's name) is embedded in the span.

Element deprivation.due-process-property: basis: summary judgment for the city, but decided "even assuming all of this is true" on the firefighters' own account of the promotion process, so recorded as [law]; the court also notes missing evidence that the city bound itself to the practice, which would read as [no-evidence].

Misfit

None recorded

B · Case × element grid

Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.

Elements 1–6 of 20

42 U.S.C. § 1983
CaseSuable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States)Action taken "under color of" state, territorial, or D.C. lawDeprivation of a right, privilege, or immunity secured by the Constitution and lawsPersonal involvement / causal connection ("subjects, or causes to be subjected")Damages remedy (legacy CASE id; not a prerequisite for prospective relief)Qualified immunity for government officials sued in individual capacity (Harlow v. Fitzgerald; Pearson v. Callahan)
Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 7–12 of 20

42 U.S.C. § 1983
CaseCommon-law absolute immunity (judicial, prosecutorial, legislative, witness functions)Eleventh Amendment state sovereign immunity bar (official-capacity damages / retrospective relief)Preiser / Heck v. Humphrey favorable-termination and habeas-exclusivity barBorrowed state personal-injury statute of limitations (42 U.S.C. § 1988; Wilson v. Garcia; Owens v. Okure)Issue preclusion / collateral estoppel from prior state criminal or civil judgment (Allen v. McCurry)Judicial standing prerequisite, separate from damages remedy
Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 13–18 of 20

42 U.S.C. § 1983
CaseStatutory bar on injunctive relief against a judicial officer acting in a judicial capacity (1996 amendment)Municipal policy or custom as moving force (Monell v. Department of Social Services)District of Columbia exclusive Act of Congress inclusion clause (1979 amendment)Rejected extra element: separate proof of "abuse of governmental power" (Collins v. City of Harker Heights)Federal action / Fifth Amendment claim (outside § 1983 state-law scope)Collateral-order appellate jurisdiction over interlocutory qualified-immunity denials (Mitchell v. Forsyth; Johnson v. Jones)
Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 19–20 of 20

42 U.S.C. § 1983
CaseAppellate preservation / forfeiture of issue not raised in district courtSection 1983 malicious prosecution claim (Fourth Amendment / procedural due process)
Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025 (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
Eveland v. City of St. Louis — 142 F.4th 1053 (2025) · United States Court of Appeals for the Eighth Circuit · 2025 — not · law (42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Protected property interest under the Due Process Clause (Board of Regents v. Roth)not
Counted merits instance
applied / merits

basis: law; party: City of St. Louis; count: procedural due process claim for failure to promote to fire captain / battalion chief; theory: regular practice of promoting the top scorer as the source of a legitimate claim of entitlement; subject: party=City of St. Louis; count=procedural due process claim for failure to promote to fire captain / battalion chief; theory=regular practice of promoting the top scorer as the source of a legitimate claim of entitlement

A regular practice of promoting the highest scorer, and the chief's intention to follow it, did not limit his discretion and so created only an expectation, not a property interest. The same reasoning disposed of the takings claim.
expected promotion from an exam shortlist where the fire chief had always picked the top scorer but kept discretion; promotions frozen by a superior
Under the present fire chief, this person has invariably been the highest scorer.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [2294:2375] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

And if this practice had continued, as the fire chief intended, each of the firefighters would have received a promotion because each would have been the highest scoring candidate for a vacancy.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [2376:2570] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

From these candidates, the fire chief may select one person to promote.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [2222:2293] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

What is missing is evidence that the city bound itself in some fashion to adhere to that practice.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [3675:3773] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: fact; polarity: cuts-against; absent flag: 1; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

“An employee’s unilateral expectations spawned by the regularized practices of his employer will not do.”
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [3282:3387] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 1 (1 = tagged; 0 = not tagged)

Even assuming all of this is true, the firefighters had no property interests in their desired promotions that the due process clause protected.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1053; Unicode character offsets [2931:3075] (end exclusive); SHA-256 50f302e701981b47911f5f08e36131f9b9913a86e8e39648b1b36352b9b4b215.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case