Mitchell Sanderson v. Walsh County Sheriff
CourtCourt of Appeals for the Eighth Circuit
Date FiledOctober 23, 2026
Docket26-1550
StatusUnpublished
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Full Opinion
United States Court of Appeals
For the Eighth Circuit
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No. 26-1550
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Mitchell S. Sanderson
Plaintiff - Appellant
v.
Walsh County Sheriff, Ron Jurgens
Defendant - Appellee
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Appeal from United States District Court
for the District of North Dakota - Eastern
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Submitted: October 20, 2026
Filed: October 23, 2026
[Unpublished]
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Before STRAS, KOBES, and JUSTIN D. SMITH, Circuit Judges.
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PER CURIAM.
Mitchell Sanderson alleged that he was prevented from commenting on the
Walsh County Sheriff Office’s Facebook page. We affirm the district court’s 1 grant
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The Honorable Peter D. Welte, Chief Judge, United States District Court for
the District of North Dakota, adopting the report and recommendations of the
of summary judgment to Sheriff Ron Jurgens. See Bedford v. Doe, 880 F.3d 993,
996 (8th Cir. 2018) (reviewing summary judgment de novo).
He is entitled to it in his individual capacity because there is no evidence that
he was “personal[ly] involve[d]” in the decision to block Sanderson. Davis v. City
of Little Rock, 122 F.4th 326, 331 (8th Cir. 2024) (“To prevail on a § 1983 claim, a
plaintiff must show each individual defendant’s personal involvement in the alleged
violation.” (citation omitted)). Nor was there proof that an official policy, practice,
or failure to train was to blame, which takes care of the official-capacity claim. See
Atkinson v. City of Mountain View, 709 F.3d 1201, 1214 (8th Cir. 2013) (identifying
the grounds for municipal liability and explaining that “solely . . . employ[ing] a
tortfeasor” is not enough (citation omitted)). As for the district court’s refusal to
wait for additional discovery before granting summary judgment, Sanderson could
not show that “the facts [he] sought exist[ed].” Anzaldua v. Ne. Ambulance & Fire
Prot. Dist., 793 F.3d 822, 837 (8th Cir. 2015) (citation omitted); see id. at 836
(emphasizing the district court’s “wide discretion” (citation omitted)).
We accordingly affirm the judgment of the district court. See 8th Cir. R. 47B.
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Honorable Alice R. Senechal, United States Magistrate Judge for the District of
North Dakota.
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