Allegation: City of Helena-West Helena, Ark. woman pays fines, but instead of documenting the payment, the Phillips County District Court clerk’s office issues an arrest warrant against her for unpaid fines. She is arrested and her car towed before the mistake is discovered. She sues the city, alleging an unconstitutional policy of not documenting fine payments. District court: Aha! But the clerk is a state official, not a city official, so you shouldn’t have sued the city. Eighth Circuit: Double aha! The law making Arkansas district courts part of state government wasn’t fully implemented in Phillips County until 2017—after the alleged constitutional violations. So maybe the clerk was a city official after all. The case can proceed.