Summary
The United States District Court for the Eastern District of Michigan granted Alpena County’s motion to dismiss a Fourteenth Amendment procedural due process claim arising from the forfeiture and eviction of the plaintiff from property purchased under a land contract. The court held that, although the plaintiff adequately alleged a due process violation, she did not plead facts establishing municipal liability under Monell. The court dismissed the federal claim with prejudice, declined supplemental jurisdiction over the remaining state-law claims, and remanded those claims to the Alpena County Circuit Court.
Court
United States District Court for the Eastern District of Michigan, Northern Division
Jurisdiction
United States District Court for the Eastern District of Michigan, Northern Division
Decision date
January 8, 2026
Docket number
1:25-cv-12588
Disposition
reversed_and_remanded
Questions Presented
- Whether Smarr pleaded facts sufficient to impose municipal liability on Alpena County under Monell and 42 U.S.C. § 1983 for the alleged deprivation of procedural due process.
- Whether the court should exercise supplemental jurisdiction over the remaining state-law claims after dismissing the federal claim.
Holdings
- The complaint failed to state a Monell claim against Alpena County because it did not plausibly allege that a County policy or custom, inadequate training or supervision resulting from deliberate indifference, or policymaker ratification caused the constitutional injury.
- Smarr alleged a protected property interest in the possession and use of the real estate and facts indicating that eviction without notice or an opportunity to be heard violated procedural due process, but the alleged violation was not attributable to Alpena County under Monell.
- The court declined to exercise supplemental jurisdiction over the remaining state-law claims after dismissing the only federal claim and remanded those claims to the Alpena County Circuit Court.
Court Document
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