Wells v. Hanneman

Background

Amir Rahkare Locke was asleep on a couch in an apartment when a Minneapolis Police Department SWAT team entered early on February 2, 2022, to execute a no-knock search warrant for a murder suspect. Mark Hanneman, a Minneapolis police officer and member of the SWAT team, shot and killed Amir after seeing a handgun in Amir’s hand.

Karen Wells and Andre Locke, acting as co-trustees for Amir’s next of kin, sought damages from Hanneman in his individual capacity and from the City of Minneapolis. Their claims included a claim under 42 U.S.C. § 1983 that Hanneman violated Amir’s Fourth Amendment right against unreasonable seizures; claims that the City maintained unconstitutional policies or customs and failed to train its officers adequately; and a Minnesota wrongful-death claim.

Motion and Video Evidence

The defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The court applied the same standard used for a motion to dismiss for failure to state a claim: it accepted the complaint’s factual allegations as true, drew reasonable inferences for the plaintiffs, and considered whether the allegations plausibly supported relief.

The court held that the SWAT officers’ body-camera videos could be considered because videos of the incident were necessarily connected to the pleadings. But the court found that the videos’ images of the critical moments were dim and unclear. They did not conclusively establish the defendants’ account that Amir’s conduct justified deadly force. The court concluded that the complaint and videos left open a plausible inference that Amir was attempting to comply with officers’ commands before he was shot.

Officer Hanneman and Qualified Immunity

Qualified immunity protects government officials from damages claims unless the alleged facts show both a constitutional violation and violation of a right that was clearly established at the time. The court determined that the complaint plausibly alleged a violation of Amir’s clearly established Fourth Amendment right.

The court explained that mere possession of a firearm generally is not enough to establish an immediate threat justifying deadly force. The complaint alleged that Amir never pointed the handgun in a threatening direction, lowered the gun farther toward the ground after Hanneman ordered him to show his hands, and began raising his other hand. Because the videos did not contradict those allegations, the court found that Hanneman was not entitled to qualified immunity at the judgment-on-the-pleadings stage.

The court distinguished an Eighth Circuit case in which an officer shot an armed person who was running toward the officer and whose gun was moving as he ran. The court stated that further evidence might show Hanneman could not reasonably discern Amir’s actions in the moment, but that issue could not be resolved on the present pleadings and unclear videos.

The court also rejected the plaintiffs’ argument that the search warrant’s alleged lack of probable cause itself established that the shooting was unreasonable. The Fourth Amendment excessive-force analysis focused on the circumstances at the time of the shooting, not on events leading to it. The court further stated that the Fourteenth Amendment did not apply to this excessive-force claim because the shooting was a seizure analyzed under the Fourth Amendment.

Claims Against the City

The plaintiffs asserted that the City maintained unconstitutional practices and customs and failed to train its officers. The court rejected the City’s argument that Hanneman’s alleged immunity required dismissal of these claims.

For the policy-or-custom claim, the plaintiffs alleged that the City had policies or customs involving no-knock warrants and excessive force against people of color. They also alleged that, in 2021 and 2022, eighty percent of Minneapolis police no-knock warrants targeted Black subjects and that none targeted a non-Hispanic white subject. The court found these allegations plausible. It also explained that municipal liability does not necessarily require a finding that an individual officer is personally liable.

For the failure-to-train claim, the plaintiffs alleged inadequate training on force and no-knock warrants, knowledge by City policymakers, and a causal connection to Amir’s death. They also identified prior incidents involving no-knock warrants, alleged that the City knew of prior rights violations by Hanneman, and cited independent investigators’ findings that Minneapolis police training on the use of force was constitutionally insufficient. The court found these allegations sufficient to keep the claim in the case.

Minnesota Wrongful-Death Claim

The defendants argued that official immunity barred the Minnesota wrongful-death claim. Under Minnesota law, official immunity generally protects public officials performing discretionary duties unless they commit a willful or malicious wrong. The court found the official-immunity inquiry comparable to the federal qualified-immunity analysis here. Because the plaintiffs plausibly alleged that Hanneman’s deadly force was legally unreasonable, the court held that official immunity did not require dismissal on this record.

Disposition

The court denied the defendants’ Motion for Judgment on the Pleadings. The order did not dismiss the federal claims against Hanneman or the City, or the Minnesota wrongful-death claim.