Carlson v. University of Northwestern - St. Paul

Background

Benjamin Carlson sued the University of Northwestern–St. Paul, Jeff Snyder, Brian Sherrer, the City of Roseville, and three Roseville police officers over a 2017 encounter. The complaint alleged that Carlson was hospitalized because of mental-health issues in February 2017. After his discharge, a student reported to university officials that Carlson had experienced a mental-health crisis and had made threatening and inappropriate statements.

Later that day, Snyder, Sherrer, and three Roseville police officers confronted Carlson as he left a classroom. The officers told Carlson that he had to go with them because he was a danger to himself and others. They physically restrained him, handcuffed him to an ambulance gurney, and took him to a hospital, where he was placed on a 72-hour involuntary psychiatric hold.

Carlson brought claims under 42 U.S.C. § 1983, a federal law allowing claims for constitutional violations committed under state authority. Count I alleged that the UNW defendants violated Carlson’s Fourth Amendment rights. Count II asserted a Fourth Amendment claim against the Roseville police officers. Count III alleged that Snyder, Sherrer, and the police officers failed to intervene to stop civil-rights violations. Count IV sought to hold the City of Roseville responsible for constitutional violations under theories identified in the complaint as Monell/Canton.

Motion and analysis

The UNW defendants moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. Their motion covered Counts I and III.

The court first concluded that Carlson’s failure to respond to the motion constituted abandonment of the claims covered by the motion. On that basis, the court granted the motion.

The court also considered the claims on their allegations. Section 1983 generally applies to state actors, not private parties. A private party may be liable if it willfully participates in joint activity with state actors, but the complaint must plausibly allege a mutual understanding or meeting of the minds about violating the plaintiff’s constitutional rights.

The court found the allegations insufficient to establish that the UNW defendants acted under color of state law. The complaint alleged that Snyder called the police and an ambulance, that Snyder and Sherrer were present during the confrontation, and that the police relied on information from the UNW defendants. But the court found that these allegations did not describe a customary plan or common practice between the university defendants and the police. The complaint also did not identify any investigative steps the officers failed to take because of the UNW defendants’ conduct. As a result, the court concluded that Carlson had not plausibly alleged the required mutual understanding or meeting of the minds.

Disposition

The court granted the UNW defendants’ motion to dismiss. It dismissed Counts I and III as to the University of Northwestern–St. Paul, Jeff Snyder, and Brian Sherrer without prejudice. The order did not rule on Counts II and IV.