Williams v. City of Minneapolis Police Department

Background

Marrieo Cartez Williams, proceeding without a lawyer, sued the City of Minneapolis Police Department, Officers Mohamud Jama, Andrew Schroeder, and Jeremiah Smersruh, and John Doe defendants. He alleged that officers used excessive force when arresting him, failed to provide medical care for injuries allegedly caused during the arrest, made racist remarks, and violated federal and Minnesota law. His claims included claims under 42 U.S.C. § 1983 for alleged violations of the First, Fourth, Sixth, Eighth, and Fourteenth Amendments; a Minnesota Constitution claim; a claim under 42 U.S.C. § 1981; and negligence under Minnesota law. He also alleged that the City was vicariously liable for the officers’ conduct.

The defendants moved for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure. The court applied the same standard used for a motion to dismiss for failure to state a claim. The court considered the officers’ body-camera recordings because they were embraced by the pleadings and their authenticity was not adequately disputed.

Body-Camera Recordings and Arrest Claims

The recordings showed officers approaching Williams while he was asleep or unconscious in a damaged, smoking vehicle. Officer Jama repeatedly identified himself as a police officer, woke Williams, asked whether he was okay and needed emergency medical services, and asked whether he wanted the officers to check him. Williams declined assistance, exited the car, and walked away. Officers then observed a baggie containing what they suspected was crack cocaine, followed Williams when he fled, restrained him against a wall, handcuffed him, searched him, and placed him in a squad car.

Williams alleged that officers tasered, punched, and kicked him, including while he was on the ground and handcuffed. The court found that the recordings blatantly contradicted those allegations because they showed that the officers did not taser, punch, or kick him. The court therefore found that Williams had not plausibly alleged excessive force under the Fourth Amendment. It also found that the circumstances gave the officers sufficient reason to intervene, investigate whether a crime had occurred, and, after the suspected drugs and flight, believe that Williams may have committed an offense.

The officers were entitled to qualified immunity on the Fourth Amendment claim. Qualified immunity generally protects government officials from liability unless the facts show a constitutional violation and the violated right was clearly established at the time. The court concluded that Williams had not plausibly alleged a constitutional violation in light of the recordings.

The court rejected Williams’s First, Sixth, and Fourteenth Amendment claims related to the arrest. Williams did not allege that he was engaged in activity protected by the First Amendment, the arrest did not implicate the Sixth Amendment on the facts alleged, and excessive-force claims arising from an arrest are analyzed under the Fourth Amendment rather than the Fourteenth Amendment. The court also found that Williams’s allegations of evidence tampering were conclusory and not plausibly supported. The court stated that the recordings contradicted his allegations of racist remarks as well.

Medical-Care Claims

Williams alleged that the officers were deliberately indifferent to his medical needs under the Eighth and Fourteenth Amendments and that their conduct violated Article I, Section 5 of the Minnesota Constitution. The court dismissed the Minnesota constitutional claim because Minnesota courts had not recognized a damages cause of action for the provision at issue.

For the federal medical-care claim, Williams needed to allege both an objectively serious medical need and that the defendants actually knew of and deliberately disregarded that need. The court found that the recordings contradicted Williams’s allegation that officers used the force he described. It also found that his complaint did not describe his injuries well enough to show that they were so obvious that a layperson would recognize the need for medical attention. In addition, the complaint did not connect the officers to a duty to treat Williams after his detention in the Hennepin County Jail.

Claims Against the City

The court analyzed Williams’s claims against the City under the rule from Monell v. Department of Social Services. Under that rule, a municipality may be liable under § 1983 when an injury is caused by an official policy or an established custom, but not merely because the municipality employed an officer who allegedly committed wrongdoing.

The court found that Williams had not plausibly shown that any officer violated his constitutional rights. It also found that, even if he had shown a constitutional violation, his references to past instances of police misconduct lacked enough detail to establish a continuing and widespread municipal policy or custom of using excessive force.

Section 1981 and Negligence Claims

The court dismissed the § 1981 claim because that statute addresses racial discrimination connected to a contractual relationship, and Williams’s complaint identified no impaired contractual relationship.

The court dismissed the negligence claim because the complaint mentioned negligence but did not identify a negligence theory. The allegations described intentional conduct—tasing, punching, and kicking—rather than explaining how the officers acted negligently or how negligence caused an injury.

Disposition

The court granted the defendants’ motion for judgment on the pleadings. It denied Williams’s motion for an evidentiary hearing because he had not shown a plausible basis for liability that would justify a hearing about damages. The court dismissed Williams’s Second Amended Complaint with prejudice and directed that judgment be entered.