Benjamin v. Spiess
- Patrick Schiltz
- 0:24-cv-04524
- U.S. District Court · District of Minnesota
- 5
In Benjamin v. Spiess, Judge Schiltz dismissed the action without prejudice after finding no plausible constitutional claim and denied plaintiffs’ applications to proceed without paying filing fees.
Henry Benjamin and Harold Edwin had their action dismissed without prejudice and their applications to proceed without paying filing fees denied. The order resolved the federal court’s screening of their claims against Jeff Spiess, Sam Shafer, Trent Studer, Jeremy Sroga, Michael Milbrandt, and Braden McNair.
What happened
In Benjamin v. Spiess, Henry Benjamin and Harold Edwin were stopped while traveling in an unregistered vehicle without valid license plates. After they refused to leave the vehicle, police broke a window, removed them, arrested them, and impounded the car. Plaintiffs argued that these actions were unlawful.
The court explained that the seven claims identified by plaintiffs appeared to arise under state law, which would not give the federal court jurisdiction because diversity of citizenship was not shown. The court nevertheless read the filings generously as possibly asserting constitutional claims under a federal civil-rights law. It found those claims implausible because Minnesota required registration and plates, giving the officers probable cause to stop the vehicle, and plaintiffs had not plausibly shown that the removal, arrest, or impoundment was unreasonable.
Judge Schiltz dismissed the action without prejudice under the federal filing-fee screening statute and denied Henry Benjamin’s and Harold Edwin’s applications to proceed without paying filing fees.
The detailed version
- Benjamin v. Spiess · No. 0:24-cv-04524
- Patrick Schiltz
- Dec. 26, 2024
Background
Henry Benjamin and Harold Edwin were pulled over while traveling in a vehicle that was not registered and did not display valid license plates. According to the opinion, they refused to exit the vehicle. Police then broke one of its windows, forcibly removed them, arrested them, and impounded the vehicle. Plaintiffs contended that the vehicle was not subject to Minnesota’s registration requirements and that the stop, arrest, and impoundment were unlawful.
Plaintiffs filed a declaration and an affidavit rather than a document labeled as a complaint. The court treated those documents together as the pleading. Plaintiffs did not pay the filing fee and instead applied to proceed without paying it.
Jurisdiction and screening
The court said that each of the seven legal claims identified by plaintiffs arose under state law. Because the claims therefore did not arise under the Constitution, federal laws, or treaties, and because there was no reason to believe that plaintiffs and defendants were citizens of different states, the court stated that it would lack subject-matter jurisdiction if plaintiffs were seeking relief only under state law.
Because plaintiffs were not attorneys, the court gave their pleading a generous interpretation. It found that the pleading at least suggested possible constitutional claims against people acting under color of state law. Such claims could arise under 42 U.S.C. § 1983, a federal civil-rights statute, giving the court federal-question jurisdiction.
The court then screened those possible federal claims under 28 U.S.C. § 1915(e)(2)(B)(ii), which requires dismissal when a filing by a person seeking to proceed without paying fees fails to state a claim for relief. The court accepted factual allegations as true for this review but disregarded legal conclusions presented as facts.
Court’s analysis
The court held that plaintiffs had not plausibly alleged a violation of their federal constitutional rights. It said Minnesota law required registration of motor vehicles, with exceptions that did not apply to plaintiffs, and required registered vehicles to display plates and other identifying insignia. Because plaintiffs admitted that the vehicle lacked those things, the court concluded that they were not authorized to operate it.
The court therefore found that defendants had probable cause to suspect a violation of Minnesota law and that the traffic stop was lawful. It also found that plaintiffs had not plausibly alleged that the later actions, including their forcible removal from the vehicle and arrest, were unreasonable under the circumstances. The court concluded that plaintiffs had not pleaded a plausible entitlement to relief under Section 1983.
Disposition
The court ordered that the matter be dismissed without prejudice under 28 U.S.C. § 1915(e)(2)(B). It separately ordered that the applications of Henry Benjamin and Harold Edwin to proceed without paying the filing fee be denied. The opinion does not list the seven state-law claims individually in the provided text.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.