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Thomas v. City of Edmundson

United States District Court, E.D. Missouri, Eastern Division

September 30, 2019

QUINTON THOMAS, et al., Plaintiffs,
v.
CITY OF EDMUNDSON, Defendant.

          MEMORANDUM AND ORDER

          RONNIE L. WHITE UNITED STATES DISTRICT JUDGE

         This matter is before the Court on the Motion for More Definite Statement filed by Defendant, the City of Edmundson ("the City"). (ECF No. 15) Plaintiffs Quinton M. Thomas and Bradley Jiles (collectively referred to as "Plaintiffs") are opposed to the motion. After careful consideration, the Court denies the City's motion.

         BACKGROUND

         Plaintiffs filed this putative class action, on behalf of themselves and others similarly situated, pursuant to 42 U.S.C. § 1983 against the City, claiming it has a deliberate policy that violates their constitutional rights. Count I of Plaintiff s Class Action Compliant alleges violations of the Fourteenth Amendment for imprisoning Plaintiffs for inability to pay; Count II alleges violations of the Sixth and Fourteenth Amendments for failure to provide adequate counsel; Count III alleges violations of the Fourteenth Amendment for subjecting Plaintiffs to indefinite and arbitrary detention; Count IV alleges violations of the Fourth and Fourteenth Amendments for issuances of invalid warrants; and Count V alleges violations of the Fourteenth Amendment for the use of threats of incarceration to collect debts. (Id. at ¶¶ 157-79)

         The City moves pursuant to Federal Rule of Civil Procedure 12(e) for the Court to order Plaintiffs to amend their complaint to provide a more definite statement. Plaintiffs oppose the motion and argue their complaint satisfies federal pleading requirements.

         LEGAL STANDARD

         Under Federal Rule of Civil Procedure 12(e), "[a] party may move for a more definite statement of a pleading to which a responsive pleading is allowed but which is so vague or ambiguous that the party cannot reasonably prepare a response." "Rule 12(e) is not designed to remedy an alleged lack of detail, rather, the Rule is intended to serve as a means to remedy unintelligible pleadings." Resolution Trust Corp. v. Fiala, 870 F.Supp. 962, 977 (E.D. Mo. 1994). However, when a "pleading fails to specify the allegations in a manner that provides sufficient notice, a defendant can move for a more definite [statement] under Rule 12(e) before responding." Whitehead v. City of St. Louis, No. 4:09CV483 CDP, 2009 WL 4430699, at *1 (E.D. Mo. Nov. 24, 2009) (quoting Swierkiewicz v. Sorema N.A., 534 U.S. 506, 512 (2002)).

         DISCUSSION

         The City argues the Court should order Plaintiffs to provide a more definite statement regarding their alleged constitutional violations. Specifically, the City wants Plaintiffs to amend their complaint to include the following:

a. Each action that each Plaintiff contends to have resulted in the violation of a constitutional right;
b. Each injury resulting therefrom; and
c. The identity of each person (by title or name) who committed each such action (i.e., whether it was the prosecutor, municipal judge, court clerk, police officer, etc.).

(ECF No. 15, at 3) The City also argues the putative class definitions are vague and uncertain.[1]

         "In an action under § 1983, a municipality . . . cannot be liable on a respondeat superior theory, but can be held liable if a constitutional violation resulted from a municipal policy or custom." AM. v. St. Louis Cty., Mo.,891 F.3d 721, 728 (8th Cir. 2018). "Only where a municipality's failure to train its employees in a relevant respect evidences a 'deliberate indifference' to the rights of its inhabitants can such a shortcoming be properly thought of as a city 'policy or custom' that is actionable under § 1983." City of Canton, Ohio v. Harris,489 U.S. 378, 389 (1989). Therefore, municipal liability will apply in two situations: "where a municipal policy is itself unconstitutional, and where the ...


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