The U.S. Court of Appeals for the Eighth Circuit vacated and remanded a district court's partial denial of qualified and official immunity claims by two former St. Louis city officials in a constitutional rights lawsuit stemming from the city's 2023 homeless encampment decommissioning efforts.
In *Simon v. Jones* (8th Cir. 2026), the appellate court reviewed claims brought by Yitzchak Simon against former Mayor Tishaura Jones and former Human Services Director Dr. Yusef Scoggin, both sued in their individual capacities. The case centers on events surrounding the controversial dismantling of a homeless encampment near St. Louis's riverfront in March 2023.
Simon, who worked as an outreach worker at St. Patrick Center, a nonprofit organization dedicated to combating homelessness that receives city funding, became a vocal opponent of the encampment decommissioning. According to court documents, Simon participated in multiple protests against the city's actions, including demonstrations at City Hall that attracted local media coverage. The plaintiff alleges he was well-known as an opponent of the decommissioning efforts.
The controversy reached a head on March 24, 2023, when Simon arrived at what appears to have been a critical juncture in the dispute, though the full details of that day's events are not specified in the available court record. The case involves both constitutional claims under federal civil rights law and state law violations.
The legal battle began when Jones and Scoggin moved for summary judgment in the U.S. District Court for the Eastern District of Missouri, invoking both qualified immunity and official immunity defenses. Qualified immunity protects government officials from liability for civil damages unless they violated clearly established statutory or constitutional rights that a reasonable person would have known about. Official immunity provides similar protections for certain governmental functions.
The district court partially denied the defendants' motion for summary judgment, finding that genuine disputes of material fact existed regarding whether the former officials were entitled to immunity protection against certain claims. This ruling meant that factual questions remained that could only be resolved at trial, preventing the court from granting immunity as a matter of law at the summary judgment stage.
However, the Eighth Circuit found the district court's analysis incomplete. In a per curiam opinion filed Feb. 13, 2026, the three-judge panel consisting of Circuit Judges Loken, Gruender, and Grasz determined that the lower court failed to properly complete its qualified and official immunity analyses.
Specifically, the appeals court held that the district court must "constru[e] the disputed facts in the light most favorable to Simon" when conducting its immunity analysis. This standard requires courts to view all factual disputes and draw all reasonable inferences in favor of the non-moving party—in this case, Simon—when determining whether immunity applies.
The ruling represents a procedural victory for Simon, as it requires the district court to conduct a more thorough analysis of the immunity claims using the proper legal standard. When courts construe facts in the light most favorable to the plaintiff, it often makes it more difficult for defendants to establish immunity, as the analysis must assume the plaintiff's version of disputed events is accurate.
The case highlights ongoing tensions between municipal authorities and homeless advocacy groups across the country. St. Louis, like many American cities, has grappled with how to address homeless encampments while balancing public health and safety concerns with the rights of unhoused individuals. The partnership between the city and St. Patrick Center to decommission the riverfront encampment reflects efforts to involve nonprofit service providers in these sensitive operations.
The litigation also demonstrates the complex legal landscape surrounding government officials' actions in addressing homelessness. Constitutional claims in such cases often involve allegations of violations of due process rights, equal protection, or cruel and unusual punishment under the Eighth Amendment, though the specific constitutional theories in Simon's case are not detailed in the available record.
For Jones and Scoggin, the remand means they must continue defending against Simon's claims without the protection of immunity, at least until the district court completes its revised analysis. If the district court again denies immunity on remand, the case would likely proceed toward trial on the merits of Simon's constitutional and state law claims.
The Eighth Circuit's decision reflects the careful balance courts must strike when evaluating immunity claims. While these doctrines protect government officials from frivolous lawsuits that might otherwise chill their willingness to make difficult decisions, they cannot shield officials who violate clearly established legal rights.
The case will now return to the Eastern District of Missouri, where the district court must conduct a fresh immunity analysis under the appellate court's guidance. The outcome of that analysis will determine whether Jones and Scoggin can escape liability or whether Simon's case will proceed to trial on the underlying constitutional and state law claims stemming from the March 2023 encampment decommissioning.