Crawford v. Van Buren County, et al.

Plaintiff brought suit under 42 U.S.C. 1983 against officials who seized numerous dogs from a kennel she ran on her property. The district court granted summary judgment in favor of defendants on plaintiff's claims and plaintiff appealed. The court concluded that the district court properly granted summary judgment on plaintiff's claims against the county under Heck v. Humphrey where plaintiff did not allege that her 163 convictions for animal cruelty had been overturned and plaintiff conceded that several of her allegations underlying such claims were past the statue of limitations. As for the 2006 claims, plaintiff failed to dispute the district court's holding that she failed to exhaust her remedy under Arkansas Rule of Criminal Procedure 15.2. Plaintiff also failed to show an unconstitutional policy or custom was the moving force behind the violation of her rights. The court further held that the district court properly granted summary judgment on plaintiff's claims against the Humane Society defendants because no evidence supported plaintiff's conspiracy allegations. Accordingly, the court affirmed the judgment.