Webb v. City of Minneapolis

Background

Robert Webb alleged that Minneapolis police officers violated his Fourth Amendment rights when they arrested him on August 22, 2021, while executing warrants for Deondre Jefferson and Darryl Billups at Portland House. The officers had no warrant for Webb. They mistakenly believed Webb was Billups, handcuffed him, pointed weapons at him, placed him in a squad car, and returned him to Portland House while they looked for Billups. The officers discovered the mistake and released Webb about 28 minutes after the arrest.

Webb asserted claims under 42 U.S.C. § 1983 against the individual officers for unreasonable seizure, false arrest, and excessive force. He also asserted a municipal-liability claim against the City of Minneapolis under Monell v. Department of Social Services, based on alleged deficient training and practices. His other claims concerned state-law false arrest and false imprisonment and alleged violations of the Minnesota Government Data Practices Act.

The court considered video recordings attached to the defendants’ answer because the pleadings referred to them. It declined to accept Webb’s allegation that a staff member told the officers they had arrested the wrong person because the video contradicted that allegation.

Rule 12(c) Standard

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 under Rule 12(b)(6). At this stage, the court generally accepts well-pleaded factual allegations as true and asks whether they plausibly support a legal claim.

Unreasonable Arrest

The court held that the officers made a reasonable mistake of fact when they arrested Webb. The officers had a facially valid warrant for Billups, information that Billups and Jefferson were inside the residence and outside their rooms, a description of Billups, and a staff member’s identification of Webb as one of the two wanted men. Webb was also found outside his room, and the officers could reasonably infer from the circumstances that he was Billups.

The court acknowledged that Webb did not exactly match the information available about Billups, including differences in height, weight, and hair appearance. But it concluded that the total circumstances made the mistaken arrest objectively reasonable. The court also considered the officers’ investigation after the arrest, including their use of the staff member’s identification and their questions about Webb’s identification card. The court concluded that the officers were not required to conduct a perfect investigation or discover the mistake sooner.

The court therefore dismissed the Fourth Amendment seizure claim in Count 1 to the extent it was based on the arrest being unreasonable. The court did not reach the officers’ separate argument that the constitutional right was not clearly established because it found no plausibly alleged constitutional violation.

Continued Detention

Webb also challenged the approximately five-minute period when officers left him handcuffed in the squad car while they briefly returned to Portland House. The court construed Webb’s failure to respond to the defendants’ arguments about this period as a concession that the continued detention did not independently violate his constitutional rights. The court dismissed this part of the claim as well.

Excessive Force

Webb alleged that pointing weapons at him and handcuffing him constituted excessive force. He argued that any force used during an unreasonable arrest was unconstitutional. Because the court had concluded that the arrest was based on a reasonable mistake, it found that Webb had not adequately alleged that the force was necessarily unreasonable. The court dismissed the excessive-force claim in Count 1.

Claim Against the City

Webb alleged that a City policy or custom, including allegedly inadequate training concerning warrant execution and implicit bias, caused the constitutional violation. The court held that because Webb had not adequately alleged a constitutional violation by the individual officers, his municipal-liability claim against the City also failed. The court dismissed Count 2.

State-Law and Data-Practices Claims

The court declined to decide whether the defendants were protected by official immunity under state law. Because it dismissed Webb’s federal claims and no other federal claims remained, the court declined to exercise supplemental jurisdiction over the state-law false-arrest and false-imprisonment claims in Count 3 and the Minnesota Government Data Practices Act claims in Counts 4 and 5. Those claims were dismissed without prejudice.

Disposition

The court granted in part and denied in part the defendants’ motion for judgment on the pleadings. Webb’s § 1983 claims against the individual officers in Count 1 and his Monell claim against the City in Count 2 were dismissed with prejudice. The state-law and data-practices claims in Counts 3, 4, and 5 were dismissed without prejudice. The court denied the motion to the extent the defendants sought dismissal of those state claims with prejudice.