Matanzo v. St. Charles County Jail, et al.

Summary

The United States District Court for the Eastern District of Missouri granted Karlo A. Matanzo’s application to proceed in forma pauperis but dismissed his § 1983 complaint without prejudice for failure to state a claim. The court held that the St. Charles County Jail and St. Charles County Court were not suable entities and that the allegations did not establish municipal liability against St. Charles County under Monell.

Holdings

1. A county jail is not a distinctly suable legal entity under § 1983.
2. A state circuit court is not a suable entity under § 1983 and is protected from such suits by state immunity under the Eleventh Amendment.
3. The complaint fails to state a § 1983 claim against St. Charles County because it does not allege facts showing that a constitutional violation resulted from an official policy, unofficial custom, or deliberately indifferent failure to train or supervise.
4. The complaint must be dismissed without prejudice because it is legally frivolous and fails to state a claim upon which relief can be granted.

Questions Presented

1. Whether St. Charles County Jail and St. Charles County Court are suable entities under 42 U.S.C. § 1983.
2. Whether the complaint states a § 1983 claim against St. Charles County under a municipal-policy, custom, or failure-to-train-or-supervise theory.
3. Whether the complaint was subject to dismissal on initial review under 28 U.S.C. § 1915(e)(2).

Disposition

dismissed