Independent State Actors, Municipal Garbage-Fee Prosecutions, and the Limits of Monell and RICO Liability

Commentary on Santori Little v. The City of Valley, Alabama, No. 24‑10120 (11th Cir. Nov. 25, 2025) (unpublished)

I. Introduction

This Eleventh Circuit opinion sits at the intersection of three recurring modern litigation themes:

Efforts to challenge municipal “criminalization of poverty” practices, here involving jailing and high bail for unpaid garbage fees;
The demanding standards for municipal liability under 42 U.S.C. § 1983 after Monell;
The increasingly frequent attempt to recast ordinary government–vendor relationships as Racketeer Influenced and Corrupt Organizations Act (RICO) “enterprises.”

In Little v. City of Valley, residents of Valley, Alabama—Santori Little, Charles Gray, and Tamara Khelifa—brought a putative class action under § 1983 and RICO against:

The City of Valley (a municipality that bills and collects garbage fees and initiates criminal complaints for nonpayment), and
AmWaste, LLC (a private company that physically collects the garbage under contract with the City).

They alleged that Valley routinely jailed residents and subjected them to $2,500 bail for failure to pay garbage-collection bills, in violation of the Eighth (excessive bail) and Fourteenth (due process) Amendments, and that Valley and AmWaste together formed a RICO “association-in-fact enterprise” to extort garbage fees.

The Eleventh Circuit affirmed dismissal with prejudice, holding that:

The plaintiffs failed to satisfy Monell’s threshold requirements for municipal liability, because the relevant decisions (arrest warrants and bail) were made by independent state judicial and prosecutorial actors, not by the City; the independent decisions of those state actors broke the causal chain as a matter of § 1983 causation doctrine; and
The RICO claim failed at the “enterprise” element because an ordinary, arms-length garbage-service contract between a city and a hauler, with the vendor paid a fixed fee for lawful services, does not plausibly constitute an “association-in-fact enterprise” with a shared criminal purpose.

Although unpublished and thus non-precedential within the Eleventh Circuit, the opinion cogently applies and synthesizes several important doctrines, especially:

How independent state prosecutors and judges
The “authority and responsibility” test under Monell for attributing acts to a municipality; and
The “shared criminal purpose” requirement for RICO association-in-fact enterprises under Cisneros v. Petland and related cases.

II. Factual and Procedural Background

A. Municipal Garbage Fees and Criminal Nonpayment

Valley is an Alabama municipality that:

Charges residents a monthly garbage collection fee;
Outsources all physical garbage pickup to AmWaste, LLC, a private contractor; and
Retains responsibility for billing and collection of fees.

Important structural facts the Court emphasizes:

AmWaste “only handles garbage collection,” and its compensation is not tied to how many residents pay their garbage bills.
The City, not AmWaste, handles the money: Valley “handles all billing and collection and retains what remains after AmWaste is paid.”
When residents fail to pay, Valley files criminal misdemeanor complaints for nonpayment, invoking Alabama Code §§ 22‑27‑3 or 22‑27‑5.

B. How the Plaintiffs Ended Up in Jail

The three named plaintiffs—Little, Gray, and Khelifa—did not pay their garbage bills. Valley responded in a standardized way:

Valley filed misdemeanor complaints against each plaintiff in the District Court of Chambers County, Alabama (a state court).
The charges alleged violations of the Alabama Code, not municipal ordinances.
A state prosecutor from the District Attorney’s Office, who possessed full prosecutorial discretion, handled the prosecutions.
A state district judge or magistrate issued arrest warrants.
Once arrested, each plaintiff was jailed and ordered to post $2,500 bail.
All three ultimately pleaded guilty.

The plaintiffs also alleged that Valley used the “threat of jail” to coerce payment. The district court (and, implicitly, the Court of Appeals) treated this as merely a restatement of the fact that Valley initiated criminal proceedings; there were no specific allegations of direct, individualized threats beyond the initiation of prosecutions.

C. The Lawsuit and Claims

In their second amended complaint, plaintiffs asserted four core federal claims:

§ 1983 – Eighth Amendment: Valley allegedly violated the Eighth Amendment by causing the setting of excessive bail ($2,500) for failure to pay garbage fees.
§ 1983 – Fourteenth Amendment Due Process: Valley allegedly caused their jailing even though, they asserted, Alabama law does not authorize imprisonment merely for nonpayment of garbage bills.
§ 1983 conspiracy: Valley and AmWaste allegedly conspired to violate plaintiffs’ constitutional rights (bail and jailing) through a coordinated pattern of criminal complaints and collection practices.
RICO (18 U.S.C. § 1964(c)): Valley and AmWaste allegedly formed an “association-in-fact” enterprise and engaged in a pattern of racketeering activity (extortion of garbage fees) through the threat and use of criminal proceedings.

Valley and AmWaste moved to dismiss, arguing (among other things):

The § 1983 claims failed under Monell because the critical decisions were made by state officials (judges and prosecutors) acting on behalf of the state, not by municipal officials, and no City “policy or custom” caused the alleged constitutional violations.
The § 1983 conspiracy claim lacked factual allegations of any agreement to violate constitutional rights.
There was no RICO “enterprise”; at most, the complaint alleged a normal commercial contract between a city and a vendor, with a generalized profit motive.

The district court agreed and dismissed with prejudice. On appeal, the plaintiffs raised only the sufficiency of their § 1983 and RICO pleadings (Valley also raised several jurisdictional and alternative grounds; those are addressed briefly in the opinion).

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit, per curiam, affirmed dismissal of all claims. The key holdings are:

A. § 1983 and Monell Liability

No municipal authority over the challenged function. Under Monell and its Eleventh Circuit progeny, a municipality can only be liable where it has “authority and responsibility” over the governmental function in question. Here, the function that allegedly violated plaintiffs’ rights—issuing arrest warrants and setting bail—was performed by state judges and magistrates, and prosecution decisions were made by state prosecutors, not by the City.
Independent state decision-makers break the causal chain. Even accepting that Valley filed the misdemeanor complaints, the deliberate and autonomous decisions of state prosecutors and judicial officers to prosecute, arrest, and set bail severed any causal connection between the City’s filings and the alleged constitutional injuries.
No viable § 1983 conspiracy claim. Because the underlying § 1983 claims failed (no municipal causation), the § 1983 conspiracy claim necessarily failed as well.

B. RICO

The Court also rejected the RICO claim:

No association-in-fact enterprise. The complaint did not plausibly allege that Valley and AmWaste shared a common criminal purpose to extort garbage fees. AmWaste’s role was limited to standard garbage collection for a fixed fee—“a wholly innocent activity undertaken as a course of regular business.”
Mere profit motive is insufficient. A general desire by each party to earn money from its own legitimate endeavor does not satisfy RICO’s “shared purpose” requirement for an enterprise; the plaintiffs needed to allege a shared purpose to enrich themselves through a particular criminal course of conduct, which they did not.
Concession as to RICO conspiracy mens rea. Plaintiffs conceded that “the necessary mens rea” for a RICO conspiracy was not attributable to Valley, dooming any RICO conspiracy theory against the City in any event.

The Court also addressed and rejected two threshold jurisdictional objections:

Rooker–Feldman did not bar the claims because plaintiffs sought damages for alleged constitutional violations during the proceedings, not reversal of their state-court convictions.
The statute of limitations on Little’s claims, even if expired, would be an affirmative defense, not a jurisdictional defect, and thus did not deprive the court of subject-matter jurisdiction.

IV. Detailed Analysis

A. § 1983, Monell, and Municipal Liability

1. The Governing Framework: Monell and Its Elements

Monell v. Department of Social Services, 436 U.S. 658 (1978), established that municipalities are “persons” for purposes of § 1983 but can be liable only for constitutional violations caused by:

An official policy (e.g., statute, ordinance, or regulation),
A custom or practice so widespread as to have the force of law, or
The decisions of officials whose acts may fairly be said to represent official policy.

The Eleventh Circuit restates its familiar three-element test (from Underwood v. City of Bessemer, 11 F.4th 1317 (11th Cir. 2021), citing McDowell v. Brown, 392 F.3d 1283 (11th Cir. 2004)):

A constitutional right was violated;
The municipality had a policy or custom constituting “deliberate indifference” to that right; and
The policy or custom caused the violation.

Additionally, as emphasized in Teagan v. City of McDonough, 949 F.3d 670 (11th Cir. 2020), there is a threshold question:

“[A] plaintiff must show that the [municipality] has authority and responsibility over the governmental function at issue before the municipality can be held liable under Monell.”

Thus, if the challenged conduct was not performed by officials acting “on behalf of” the municipality, there is no municipal liability—even if the municipality’s actions set the broader context of what occurred.

2. Who Was Acting “On Behalf Of” Whom?

Plaintiffs argued that Valley had a policy of criminally prosecuting residents for failing to pay garbage fees and that this custom “began the causal chain” that led to their arrests and excessive bail. The Eleventh Circuit disagreed, focusing sharply on the identity and role of the actors who made the critical decisions.

State judges and magistrates. The warrants and bail orders were issued by judges and magistrates of the Alabama District Court, a “state trial court whose jurisdiction is established by state law,” see Ala. Code § 12‑12‑32(a). These judicial officers were serving in a state capacity, not as municipal policymakers.
State prosecutors. The prosecutions were managed by the Chambers County District Attorney’s Office, whose attorneys exercised full prosecutorial discretion over whether to prosecute, dismiss, or negotiate pleas.

Citing Teagan and Turquitt v. Jefferson County, 137 F.3d 1285 (11th Cir. 1998) (en banc), the Court reiterated that:

Judges “act on behalf of the state, and not on behalf of the municipality, when [they] engage[] in judicial acts for the purpose of applying or enforcing a state law.”
Local governments “can never be liable under § 1983 for the acts of those whom the local government has no authority to control.”

Here, the judges and magistrates were applying state statutes—Alabama Code §§ 22‑27‑3 and 22‑27‑5—in a state court, under state-granted jurisdiction. Similarly, the District Attorney’s Office is a state prosecutorial authority, not subject to municipal policy control. Accordingly, Valley lacked “authority and responsibility” over the arrest and bail decisions that directly formed the basis for plaintiffs’ constitutional claims. This alone is a substantial barrier to Monell liability.

3. Causation and the Role of Independent State Actors

The Court then layered in the separate but related doctrine that independent, deliberative decision-makers can break the causation chain for § 1983 liability.

Under Dixon v. Burke County, 303 F.3d 1271 (11th Cir. 2002):

“[T]he causal relation does not exist when the continuum between the defendant’s action and the ultimate harm is occupied by the conduct of deliberative and autonomous decision-makers.”

This principle was recently clarified in Coley‑Pearson v. Martin, -- F.4th --, 2025 WL 2910579 (11th Cir. Oct. 14, 2025):

The key question is whether the intervening actor retained “individual freedom of rational choice” and acted according to his or her “individual free will.”
If so, that actor’s decision breaks the causal chain that would otherwise connect the defendant’s initial conduct to the plaintiff’s injury.
If not (for example, because the decision-maker was coerced or lacked discretion), the chain may remain intact.

Applying this framework, the Eleventh Circuit observed that:

Although Valley initiated the criminal proceedings by filing complaints, the actual arrests, prosecutions, and bail determinations “stemmed from the conduct of deliberative and autonomous decision-makers”—the state prosecutors and judges.
Those actors retained full “individual free will”:
- The prosecutor could have declined to prosecute.
- The judge could have refused to issue an arrest warrant, set a lower bail, or released plaintiffs on recognizance.

The Court analogized to two prominent Eleventh Circuit precedents:

Turner v. Williams, 65 F.4th 564 (11th Cir. 2023): A sheriff’s alleged retaliatory motive could not be deemed the legal cause of a deputy’s arrest when an independent prosecutor and judge made their own decisions to prosecute and issue an arrest warrant.
Carruth v. Bentley, 942 F.3d 1047 (11th Cir. 2019): A former Alabama governor did not cause the plaintiff’s injury where a state agency, sitting in the middle of the causal chain, independently chose how to act.

Here, as in those cases, the Eleventh Circuit concluded that the “intervening conduct of independent state actors broke the causal chain” between the City’s decision to file misdemeanor complaints and whatever constitutional violations might have occurred in bail setting and imprisonment.

The opinion underscores this autonomy with a practical example: the Chambers County District Attorney later announced that his office would no longer prosecute Valley residents for nonpayment of garbage fees. That discretionary policy change—made independently of the City—underscores that the DA’s prior prosecutions were likewise an exercise of prosecutorial free will, not a mechanical or coerced outcome dictated by the City’s complaints.

4. Consequences for the § 1983 and § 1983 Conspiracy Claims

Because:

The challenged acts (issuing warrants, setting bail, choosing to prosecute) were undertaken by state (not municipal) actors; and
Those actors made independent decisions that severed the causal chain stemming from Valley’s initial filings;

the plaintiffs failed to allege that Valley, through its own policy or custom, caused their constitutional injuries. That failure on causation is independently fatal to their Eighth and Fourteenth Amendment claims against Valley under Monell.

The § 1983 conspiracy claim necessarily also fails. Under Spencer v. Benison, 5 F.4th 1222 (11th Cir. 2021), a conspiracy claim under § 1983 requires an underlying constitutional violation. Because no actionable municipal violation is established, there is nothing for the conspiracy theory to latch onto.

B. RICO and Association-in-Fact Enterprises

1. The RICO Framework

RICO makes it unlawful for any person associated with an “enterprise” engaged in interstate commerce to “conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity.” 18 U.S.C. § 1962(c).

To state a RICO claim, a plaintiff must allege:

Conduct (management or operation),
Of an enterprise,
Through a pattern,
Of racketeering activity (predicate criminal acts, such as extortion, mail fraud, wire fraud, etc.).

The key dispute here centered on the enterprise element, specifically an “association-in-fact” enterprise.

2. What Is an Association-in-Fact Enterprise?

Under 18 U.S.C. § 1961(4) and Supreme Court precedent (United States v. Turkette, 452 U.S. 576 (1981)), a RICO enterprise can be:

A formal legal entity (corporation, partnership, etc.), or
“Any union or group of individuals associated in fact although not a legal entity”—an association-in-fact enterprise.

Following Almanza v. United Airlines, Inc., 851 F.3d 1060 (11th Cir. 2017) and Cisneros v. Petland, Inc., 972 F.3d 1204 (11th Cir. 2020), the Eleventh Circuit reiterated the three structural features an association-in-fact enterprise must have:

A common purpose among the alleged participants;
Relationships among those associated with the enterprise; and
Longevity sufficient to permit the associates to pursue the enterprise’s purpose.

The focal point in this case is the purpose prong. Cisneros stressed:

A “generally shared interest in making money” is not enough to establish a common purpose.
When each participant’s “ultimate purpose is to make money for themselves,” a plaintiff must plausibly allege that they shared the purpose of enriching themselves through a particular criminal course of conduct.
The complaint must plausibly support an inference that defendants were collectively trying to make money through the alleged racketeering acts, as opposed to the “obvious alternative explanation” that they were just engaging in ordinary profit-seeking business behavior.

3. Application to Valley and AmWaste

Plaintiffs contended that Valley and AmWaste formed an association-in-fact enterprise to extort garbage fees from residents via threats of criminal prosecution and jail. The Eleventh Circuit rejected this theory on both factual and doctrinal grounds.

Nature of AmWaste’s role. AmWaste’s only function was to collect garbage for a fixed fee under a contract with the City. Its compensation was not tied to how many residents paid, or to the City’s success in collecting delinquent fees, or to the imposition of fines, jail, or bail. It performed “wholly innocent activity undertaken as a course of regular business” (language borrowed from Ray v. Spirit Airlines, Inc., 836 F.3d 1340 (11th Cir. 2016)).
No shared criminal purpose. The complaint did not allege that AmWaste received any money from the alleged extortionate scheme beyond its standard contractual payments, nor that it in any way benefitted from or participated in the enforcement of garbage-fee delinquencies.

Accordingly, the Court concluded:

“The complaint leaves us only with the ‘obvious alternative explanation’ for Valley and AmWaste’s association: that Valley wanted its trash picked up and AmWaste wanted to make money doing it.”

This tracks Cisneros and Ray, which emphasize that when a defendant’s conduct is fully consistent with “anodyne” or “wholly innocent” business activity, a RICO plaintiff must plausibly exclude that innocent explanation by alleging facts that point toward a coordinated criminal endeavor—not simply a profitable relationship.

4. RICO Conspiracy and Mens Rea

The opinion additionally notes that plaintiffs conceded that the “necessary mens rea” for a RICO conspiracy is “not attributable to Valley.” Under § 1962(d), a RICO conspiracy claim requires:

An agreement to participate in the enterprise’s predicate acts, and
The requisite criminal intent.

Their concession effectively eliminated Valley as a viable RICO conspirator. Combined with the failure to plausibly allege AmWaste’s shared criminal purpose, the RICO claim collapses.

C. Threshold Jurisdictional Matters

1. Rooker–Feldman

Valley argued the case was barred by the Rooker–Feldman doctrine, which prohibits lower federal courts from acting as appellate tribunals to review final state-court judgments. Relying on Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021), the panel rejected that argument, stressing:

Rooker–Feldman is “narrow.”
It applies only where the plaintiff effectively seeks to set aside or “undo” a state-court judgment.
Here, plaintiffs sought damages for alleged constitutional violations during the proceedings, not to vacate or overturn their guilty pleas and resulting judgments.

Thus, the federal court had jurisdiction to hear the case; the claims simply failed on their merits.

2. Statute of Limitations and Subject-Matter Jurisdiction

Valley also argued that one plaintiff’s claims (Little’s) were time-barred. The Court short-circuited that as a jurisdictional argument by saying:

A statute of limitations is an affirmative defense, not a jurisdictional bar.
Citing Day v. McDonough, 547 U.S. 198 (2006), the panel observed that limitations defenses do not affect the court’s subject-matter jurisdiction.

Thus, the existence or non-existence of a limitations bar was irrelevant to the appellate court’s power to hear the case (though it could, in another case, ground dismissal on the merits).

V. Impact and Significance

A. Municipal Liability for “Debtors’ Prison”–Type Practices

This opinion will be particularly important for litigants challenging municipal practices that rely on state criminal mechanisms—for example:

Jailing for unpaid fines or fees;
Use of arrest warrants and bail to coerce payment of municipal debts; and
Contracting with private vendors while using state-court criminal processes to collect money.

It reinforces two obstacles such plaintiffs must overcome:

The “authority and responsibility” hurdle: If arrest, bail, sentencing, or incarceration decisions are made by state courts or state prosecutors applying state law, plaintiffs must either:
- Sue the relevant state actors (subject to immunity doctrines), or
- Show that those actors were in fact acting under municipal policy or lacked meaningful discretion (a high bar).
The “independent actor” causation hurdle: Even if a municipality “starts the process” by, say, filing a complaint or referring a case, an intervening independent decision-maker (judge, prosecutor, state agency) may break the proximate-cause chain, defeated by the “individual free will” doctrine highlighted in Coley‑Pearson.

For advocacy groups attacking “debtors’ prison” systems, this case underscores that structural evidence—such as showing that prosecutors and judges are effectively rubber-stamping municipal demands, or that state actors have no real discretion—may be crucial to preserving causation. Absent such allegations, suits framed solely against municipalities will often fail under Monell.

B. Clarifying the Limits of RICO in Ordinary Government–Vendor Relationships

On the RICO front, this decision aligns with a trend in the Eleventh Circuit (and elsewhere) to resist expansion of RICO to cover ordinary commercial or governmental relationships absent clear indicia of a shared criminal project.

Key takeaways:

Routine service contracts between governments and private vendors—garbage collection, towing, traffic camera operation, etc.—will not constitute RICO enterprises absent allegations that:
- The vendor shares in the illicit proceeds of the alleged scheme;
- The vendor’s compensation is tied directly to allegedly unlawful practices; or
- The vendor plays an active role in designing or implementing the criminal conduct.
A general desire to earn money is insufficient; plaintiffs must plead a shared, specific criminal purpose. Without that, courts will default to the “obvious alternative explanation” of legitimate profit-seeking.

This case provides municipalities and vendors with a roadmap for RICO-resilient structuring of contracts: fixed-fee arrangements, clear separation of roles, and absence of vendor financial upside from enforcement measures are all factors supporting a finding of “wholly innocent activity.”

C. Practical Litigation Lessons

For future plaintiffs:

To survive a motion to dismiss under § 1983 in this context, complaints must:
- Allege concrete facts showing that the municipality controls or dictates arrest and bail decisions, or that prosecutors/judges lack independent discretion (e.g., are contractually obligated, financially dependent, or acting under non-discretionary statutory schemes); and
- Specify how a municipal policy or custom directly governs those decisions.
To state a viable RICO enterprise claim, complaints must provide particularized allegations that:
- The vendor and the government entity share in unlawful financial gains from the alleged scheme; and
- The vendor’s role goes beyond ordinary contract performance into active participation in the extortion or fraud.

For municipalities and contractors:

Maintaining clear divisions between municipal financial interests and state criminal enforcement decisions (prosecutorial and judicial) can help shield against Monell liability.
Structuring vendor compensation to avoid sharing in fines, penalties, or coercive collection revenue diminishes the risk of being seen as a RICO enterprise member.

VI. Simplifying Key Legal Concepts

1. What Is § 1983?

42 U.S.C. § 1983 allows individuals to sue state and local officials (and, in certain circumstances, municipalities) when those officials, acting “under color of state law,” violate federal rights, including constitutional rights. It does not create rights by itself; it provides a mechanism to enforce rights found elsewhere (e.g., the Eighth and Fourteenth Amendments).

2. What Is Monell Municipal Liability?

Under Monell:

You cannot sue a city under § 1983 solely because one of its employees did something wrong—there is no automatic “vicarious liability” or “respondeat superior.”
Instead, you must show the city itself is responsible, typically by proving:
- There was an official policy (like a written rule), or an entrenched custom (a common practice that everyone follows),
- That policy or custom was deliberately indifferent to your rights, and
- It caused your injury.

You also must show that the person whose actions injured you was acting in a way that the law treats as on behalf of the city, not some other entity (like the state).

3. Independent Decision-Maker Breaking the Causal Chain

Imagine three steps:

The City sends your name to a prosecutor for possible charges.
The prosecutor reviews your case and decides independently to prosecute.
A judge, after hearing from both sides, sets bail.

Even if Step 1 contributed to what happened later, the law sometimes says:

The prosecutor and judge’s independent decisions are more directly responsible for your injury; and
The City is not the legal “cause” of your arrest and bail if those state actors acted with full discretion and free will.

That is what it means for a “deliberative and autonomous” actor to break the causation chain.

4. What Is RICO and an “Association-in-Fact Enterprise”?

RICO is a federal law aimed at organized crime. To use it in civil litigation, plaintiffs often argue that:

A group (among whom might be a company, a city, and private individuals) formed an “enterprise,” and
They engaged in a pattern of crimes (like fraud or extortion) to make money.

An “association-in-fact enterprise” is just a fancy name for a group of people or entities who’ve informally banded together to carry out a common purpose, which can be either lawful or unlawful. To qualify as a RICO enterprise, however:

The group must have a shared purpose,
Some structure or relationships among members, and
Enough time and continuity to pursue that purpose.

Critically, in cases like this one, if the shared purpose is simply to do business and make money in a legal way—for example, a city paying a vendor to pick up garbage and the vendor receiving a fixed fee—courts will not treat that as a RICO enterprise unless there is substantial evidence of a joint criminal scheme.

5. Rooker–Feldman in Plain Terms

Rooker–Feldman is a doctrine that says:

If you lose in state court, you cannot go to a federal district court and ask it to reverse or void the state-court judgment.
Only the U.S. Supreme Court can review final state-court decisions.

But you can still go to federal court to seek damages for things that went wrong along the way (for example, unconstitutional practices during your prosecution), so long as you’re not effectively asking the federal court to nullify the state judgment itself.

VII. Conclusion

Little v. City of Valley illustrates how powerful, and constraining, the doctrines of Monell municipal liability, § 1983 causation, and RICO enterprise can be.

On the § 1983 side, the Eleventh Circuit held that Valley cannot be held responsible for arrest warrants and bail decisions made by state judges and prosecutors exercising independent, state-derived authority and discretion. Regardless of how troubling the underlying practice of criminalizing unpaid garbage fees might appear, the Court concluded that the municipality neither had the requisite “authority and responsibility” over the challenged function nor satisfied the causation requirement in light of intervening, autonomous state actors.

On the RICO side, the decision reinforces that an ordinary, arms-length contract between a municipality and a vendor—even one operating within a controversial enforcement regime—does not amount to an association-in-fact enterprise without allegations of shared criminal intent and benefit. A general profit motive and standard service provision are insufficient to transform a municipal services contract into a RICO enterprise.

For future litigants challenging systems that blend municipal finances, private contractors, and state criminal enforcement, this case underscores the need for:

Careful identification of who actually controls and decides arrest, bail, and incarceration;
Specific factual allegations showing how a municipal policy or custom directly governs or dictates those decisions; and
Concrete evidence that private contractors share in, or help design, the criminal aspects of the alleged scheme, rather than simply being paid for routine, lawful services.

Although unpublished and nonbinding, Little is a clear and instructive application of established Eleventh Circuit doctrine. It will be a persuasive citation in future § 1983 and RICO litigation where municipalities and their contractors face claims arising from the use of state criminal processes to enforce local financial obligations.

Independent State Actors, Municipal Garbage-Fee Prosecutions, and the Limits of Monell and RICO Liability: Commentary on Santori Little v. City of Valley