Robert T. King v. City of St. Louis

Summary

The United States District Court for the Eastern District of Missouri denies the St. Louis Board of Police Commissioners’ motions to substitute itself for the City of St. Louis and to substitute counsel under Federal Rule of Civil Procedure 25(c). The court concludes that substitution is inappropriate because the Board withdrew its consent, asserted defenses unavailable to the City, and substitution could prejudice the plaintiff. The plaintiff’s ADA and Missouri Human Rights Act claims therefore remain pending against the City, without prejudice to other mechanisms for adding or removing parties.

Holdings

1. Substitution was not appropriate under the circumstances because the Board withdrew its consent, sought to assert Eleventh Amendment immunity unavailable to the City, and substitution could prejudice King.
2. Denial of substitution did not foreclose other mechanisms for adding the Board, including an amended complaint, joinder, or impleader.

Questions Presented

1. Whether the St. Louis Board of Police Commissioners should be substituted for the City of St. Louis under Federal Rule of Civil Procedure 25(c).
2. Whether substitution should be denied because the Board withdrew its consent, would assert defenses unavailable to the City, and substitution could prejudice the plaintiff.

Disposition

other