Tamatrice Williams v. City of Sherwood, Arkansas

State law determines whether an entity is a state or a local entity for purposes of Section 1983 liability. McMillian v. Monroe County., 520 U.S. 781, 785–86 (1997). On January 23, 2020, the Arkansas Supreme Court held as a matter of first impression that local courts not yet reorganized into Arkansas state courts—like the Sherwood court at issue in this case—were municipal courts under the control of the municipality. City of Little Rock v. Nelson, 592 S.W.3d 633, 641 (Ark. 2020). Five days later, an Eighth Circuit panel, without citing City of Little Rock, held that Sherwood’s district court was an Arkansas state court over which Sherwood had no control. The question presented is: Should the opinion below be vacated, and this case remanded, for reconsideration in light of City of Little Rock v. Nelson?