Missouri Court of Appeals, Western District / Date unavailable
State of Missouri ex rel Andrew Bailey, Missouri Attorney General vs. Ronnie Pope
Ronnie Pope, a former pre-trial detainee, appealed a judgment ordering him to reimburse the State of Missouri under the Missouri Incarceration Reimbursement Act (MIRA) from a $20,000 settlement he received from a 42 U.S.C. section 1983 claim against the City of St. Louis. Pope argued that MIRA was preempted by federal law. The appellate court affirmed the trial court's judgment, holding that MIRA was not preempted by section 1983 because the State was not recouping funds it paid to satisfy a judgment against its own employees, and the deterrence effect on the City of St. Louis was not undermined.