PATRICK J. SCHILTZ, District Judge.
Plaintiff Jason Cox alleges that he was falsely imprisoned in the Dakota County Jail for over a month because defendants failed to comply with a pretrial-release order. Cox brings a claim under 42 U.S.C. § 1983 against Dakota County ("the County") for violating his rights under the Fourth and Fourteenth Amendments. Cox also brings a state-law false-imprisonment claim against the County. Cox has agreed to dismiss all of his remaining claims without prejudice, including his § 1983 claim against the Doe defendant. See ECF No. 17 at 5, 11.
This matter is before the Court on the County's motion for summary judgment. For the reasons stated below, the Court grants the motion as to Cox's § 1983 claim against the County and declines to exercise supplemental jurisdiction over his remaining state-law claim.
In May 2011, Cox was being held in the Dakota County Jail pending a state criminal prosecution. On May 5, 2011, Cox appeared before Dakota County District Judge Patrice Sutherland for an omnibus hearing. Cox Aff. ¶ 3. During the hearing, Judge Sutherland issued a verbal order that Cox was to be "released to other holds." Cox Aff. ¶ 5. Judge Sutherland also issued a written order with a handwritten notation stating "release to other holds." Cox Aff. ¶ 5 & Ex. A. A sheriff's deputy escorted Cox to and from the hearing and was present throughout the hearing, after which the deputy was handed a copy of Judge Sutherland's order. Cox Aff. ¶¶ 3, 5-6.
After Cox returned to the jail, a staff member emailed the Clerk of Court for the First Judicial District (which includes the County) asking for court-disposition documents for Cox and another detainee.
Summary judgment is appropriate "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). A dispute over a fact is "material" only if its resolution might affect the outcome of the lawsuit under the substantive law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute over a fact is "genuine" only if "the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Id. "The evidence of the non-movant is to be believed, and all justifiable inferences are to be drawn in his favor." Id. at 255.
Cox alleges that the County falsely imprisoned him in violation of his constitutional rights.
This policy is not facially unconstitutional, however. To hold the County liable, therefore, Cox must show that this policy exhibited deliberate indifference to his constitutional rights. See Szabla v. City of Brooklyn Park, 486 F.3d 385, 390 (8th Cir. 2007). "A policy is deliberately indifferent to a person's constitutional rights when its inadequacy is both obvious and likely to result in the alleged deprivation of constitutional rights." Russell v. Hennepin Cnty., 420 F.3d 841, 847 (8th Cir. 2005).
Cox cannot meet this standard. There is no evidence that anyone other than Cox has ever been mistakenly detained as a result of the County's policy, nor is there any evidence that the County's policy provides an inadequate means for jail staff to receive accurate information about the disposition of criminal defendants awaiting trial. In the absence of such evidence, there is nothing obviously inadequate about relying on jail and court staff to communicate with each other through informal channels regarding the custodial status of criminal defendants. Criminal defendants are, after all, normally represented by counsel, which provides an extra layer of protection in the event of a miscommunication. Assuming that Cox was unlawfully detained — an issue on which the Court expresses no opinion — those safeguards did not work in this case.
The Court therefore grants defendants' motion as to Cox's § 1983 claim against the County. Because there are no remaining claims over which the Court has original jurisdiction, the Court declines to exercise supplemental jurisdiction over Cox's remaining state-law false-imprisonment claim. See 28 U.S.C. § 1367(c)(3); Hervey v. Cnty. of Koochiching, 527 F.3d 711, 726-27 (8th Cir. 2008). That claim is dismissed without prejudice.
Based on the foregoing, and on all of the files, records, and proceedings herein, IT IS HEREBY ORDERED THAT:
LET JUDGMENT BE ENTERED ACCORDINGLY.