United States Court of Appeals for the Eighth Circuit · 2025-07-08
42usc1983: author: Flash1 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
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
| Case | Suable "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. law | Deprivation of a right, privilege, or immunity secured by the Constitution and laws | Personal 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
| Case | Common-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 bar | Borrowed 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
| Case | Statutory 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
| Case | Appellate preservation / forfeiture of issue not raised in district court | Section 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
| Case | Element | Holding and scope | Pattern | Exact 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.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.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.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.“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.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. |