Blackwell v. City of Richfield Does

Background

Richard Preston Blackwell alleged that, on July 21 and 22, 2018, unnamed Richfield police officers failed to investigate his reports of sexual assault, theft, property damage, and stalking. He alleged that officers handcuffed him, placed him in a squad car, searched his vehicle without permission, and transported him to Hennepin County Medical Center. He further alleged that unnamed medical professionals restrained him and administered sedatives and neuroleptic medication over his objection. Blackwell alleged that he was discharged while still affected by the medication.

Blackwell asserted claims under 42 U.S.C. §§ 1981, 1983, and 1988, along with Minnesota state-law claims. He did not pay the filing fee and applied to proceed without paying it. The court therefore conducted an initial review required for applicants proceeding without paying the filing fee, asking whether the complaint stated a claim for relief.

Section 1983 Claims

The court dismissed Blackwell’s individual-capacity claims against the unnamed defendants. An individual-capacity claim seeks to hold a particular government official personally responsible for violating the plaintiff’s federal rights. Blackwell named only unidentified defendants, including “City of Richfield Does,” “Richfield Police Department Does,” and “Unknown Does.”

The court explained that the six-year limitations period for a 42 U.S.C. § 1983 claim in Minnesota applied to these claims. The events occurred on July 21 and 22, 2018, and Blackwell filed his complaint on July 16, 2024. The court concluded that an amendment identifying the unnamed defendants would be futile because, under Eighth Circuit precedent, a plaintiff’s lack of knowledge of an unnamed defendant’s identity does not allow the later amendment to relate back to the original filing date.

The court also dismissed the official-capacity claims. An official-capacity claim is treated as a claim against the government entity that employs the official. A city or county generally is not liable under § 1983 merely because an employee allegedly acted unlawfully. The plaintiff must allege that the conduct resulted from an official policy or an established, widespread practice. The court found that Blackwell did not allege facts showing that the Richfield officers acted under a Richfield policy or custom, or that Hennepin County Medical Center staff acted under a policy or custom when they restrained him and administered medication. The court therefore dismissed the official-capacity claims.

Other Federal Claims

The court found that Blackwell cited 42 U.S.C. § 1981 but did not successfully assert a claim under it. Section 1981 protects, among other things, the right to make and enforce contracts and to receive the full and equal benefit of the law. The court found no facts suggesting that the defendants interfered with Blackwell’s ability to enter into or enforce a contract. To the extent he intended to assert a claim concerning the equal benefit of laws, the court applied the same reasoning that defeated his individual-capacity § 1983 claims: he had not identified a defendant, and an amendment would be futile.

The court also found that 42 U.S.C. § 1988 does not create an independent private claim. Instead, it provides remedies related to other federal civil-rights causes of action. Because Blackwell had not pleaded a viable federal civil-rights claim, the court concluded that he could not obtain relief under § 1988.

State-Law Claims and Order

Because no viable federal claim remained, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over Blackwell’s Minnesota claims.

The court ordered:

Chief Judge Patrick J. Schiltz directed that judgment be entered accordingly.