Alvarado v. Moore

Background

Juan Alvarado sued Isaiah Moore, Matthew McNeely, Joseph LeFevere, Matthew Blomsness, Joseph Huettl, and Thomas Martinez, each in an individual capacity as an officer of the St. Louis Park Police Department, along with the City of St. Louis Park. He alleged an excessive-force claim against the officers and failure-to-train and municipal-liability claims against the City.

On April 16, 2023, police received a report of a gunpoint carjacking involving a green 2015 Jeep Patriot. Dispatch reported that tracking information placed the stolen vehicle in a Goodwill parking lot. Officers saw Alvarado’s gray 2012 Jeep Patriot in that lot and believed it might contain the three armed suspects. As the officers approached, Alvarado put his car in reverse. Officer McNeely’s squad car struck the driver’s side of Alvarado’s car, and Officer Huettl’s squad car struck the rear of the car. Other officers positioned their vehicles nearby.

The officers initially exited with guns drawn and ordered Alvarado to raise his hands. They soon learned that the license plate and vehicle description did not match the stolen vehicle. The officers progressively holstered their weapons, removed Alvarado from the car, briefly handcuffed him, and released him after approximately ten seconds when a vehicle identification-number check confirmed that his car was not the stolen vehicle. Alvarado later received treatment for a minor shoulder injury and a trauma-related disorder.

Legal standard

The defendants moved to dismiss under Rule 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim. The court generally accepts the complaint’s factual allegations as true and draws reasonable inferences for the plaintiff, but it may consider videos embraced by the complaint. If video evidence plainly contradicts the complaint, the court need not accept the plaintiff’s version; inconclusive video evidence must be viewed in the plaintiff’s favor.

The officers asserted qualified immunity. Qualified immunity protects government officials from civil liability unless their conduct violated a constitutional or statutory right that was clearly established at the time. For the excessive-force claim, the court examined whether the force was objectively reasonable under the circumstances, including the seriousness of the suspected crime, the threat posed, and whether the person was resisting or attempting to flee.

Court’s analysis

The court rejected each of Alvarado’s three excessive-force theories. First, it found that McNeely and Huettl’s contact with Alvarado’s car was reasonable. The officers believed the car might contain three armed carjackers, had discussed the risk of crossfire, and could reasonably have interpreted Alvarado’s reversing car as an attempt to flee. The officers also slowed before making contact, so the impacts were not forceful.

Second, the court found that the conduct involved in removing, guiding, and handcuffing Alvarado was minor and did not exceed the force reasonably needed to carry out the arrest. LeFevere assisted Alvarado from the car without using his gun or other force, briefly directed him to place his hands on his head, and LeFevere and Moore guided him a few feet before handcuffing him for approximately ten seconds.

Third, the court found that the officers’ initial display of weapons was justified because they reasonably believed they were confronting armed carjackers. Although the officers received clues that Alvarado’s vehicle was not the stolen one, the court concluded that they did not have definitive confirmation until Huettl checked the vehicle identification number. The officers holstered their weapons as information developed and did not continue pointing guns at Alvarado after the circumstances made that force unreasonable.

Because the court found no constitutional violation, it held that the officers were entitled to qualified immunity. It dismissed Count One with prejudice.

Municipal-liability claims

The court also dismissed Alvarado’s failure-to-train and municipal-liability claims against the City. It concluded that the failure-to-train claim could not proceed because the officers were entitled to qualified immunity. It further concluded that the municipal-liability claim failed because such a claim requires an underlying constitutional violation, and the court found none here.

Disposition

The court granted the defendants’ motion to dismiss and dismissed Alvarado’s claims against the defendants with prejudice. The court directed that judgment be entered accordingly.