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Luce Successfully Represents Joyce in Stockley Appeal

On June 29, 2020, the United States Court of Appeals for the Eighth Circuit affirmed the summary judgment dismissing the civil rights and defamation claims Jason Stockley brought against former St. Louis Circuit Attorney Jennifer Joyce. David H. Luce, a Shareholder at Capes Sokol, represented Joyce in the suit.

Background:
Jason Stockley v. Jennifer Joyce

In 2011, Jason Stockley, a St. Louis Police officer, shot and killed Anthony Lamar Smith after a high-speed chase involving Smith, who was suspected of being involved in an illegal drug deal. In 2016, Joyce charged Stockley with first-degree murder and armed criminal action for the on-duty shooting of Smith. After waiving his right to a jury trial, Stockley was acquitted of murder charges by Judge Timothy Wilson in 2017.

In 2018, Stockley sued Joyce, Kirk Deeken, then a Lieutenant for the St. Louis Metropolitan Police Department, and the City of St. Louis asserting federal civil rights claims arising under 42 U.S.C. § 1983 and state law claims for malicious prosecution and defamation.

U.S. District Judge Charles Shaw granted Joyce’s motion for summary judgment in 2019 on the basis, among others, that Joyce was entitled to “absolute immunity” from Stockley’s claims because of her position as prosecuting attorney.  On appeal, the Eighth Circuit agreed.  Arguments on appeal were heard on March 11, 2020 and the Eighth Circuit filed a published opinion on June 29th, affirming the district court’s dismissal.  Regarding Stockley’s claims that Joyce’s pretrial statements violated his due process rights and amounted to defamation, the Court held: 

“Joyce’s conduct of making public statements regarding her decision to charge Stockley and the evidence supporting that decision does not remotely rise to the conscience-shocking level” and “the statements related to Stockley’s guilt reflects Joyce’s charging decision, which was supported by probable cause findings of both a state court judge and a grand jury.”

The case is Jason Stockley v. Jennifer Joyce, et al., No. 19-1573 (8th Cir. 2020).

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