Frazier v. Minneapolis, City of, The

Background

Cheryl A. Frazier brought a civil-rights action under 42 U.S.C. § 1983 and a state wrongful-death action as trustee for the next of kin of Leneal Lamont Frazier. The lawsuit named the City of Minneapolis, but not Officer Brian Cummings. The complaint alleged that Cummings was pursuing a Kia at high speeds when he ran a red light at 89 miles per hour and struck Leneal’s car. Leneal suffered severe injuries and died about an hour later. Cummings was later convicted of felony criminal vehicular homicide.

Frazier alleged that the Minneapolis Police Department had a practice of conducting unlawful high-speed pursuits of suspects in neighborhoods with disproportionately large Black populations. The City moved for judgment on the pleadings. On that motion, the court accepted the complaint’s factual allegations as true and considered whether they plausibly supported legal claims.

Substantive-Due-Process and City-Liability Claims

The court held that a high-speed police pursuit is governed by the constitutional standard requiring an intent to cause harm unrelated to the legitimate goal of arrest. The court rejected Frazier’s argument that deliberate indifference—a lower standard based on knowingly disregarding a serious risk—should apply because the complaint alleged that Cummings did not subjectively believe he was responding to an emergency.

The complaint repeatedly described Cummings as pursuing a fleeing suspect. Under the controlling rule for such pursuits, the court therefore applied the intent-to-harm standard. It found that the complaint did not plausibly allege that Cummings intended to harm Leneal, a bystander, the suspect, or anyone else. Alleging that injury was a natural and probable consequence of the reckless pursuit was not enough to establish intent to harm.

Because the complaint did not plausibly allege an underlying constitutional violation, the court held that Frazier could not establish municipal liability against the City based on an official policy or custom or on alleged failures to train or supervise. The court noted that Cummings’s conduct was criminal and had tragic consequences, but explained that substantive due process does not convert every state-law tort into a federal constitutional claim.

Race-Discrimination Claims

Frazier asserted equal-protection and Title VI claims based on alleged racial profiling in the selection of neighborhoods for high-speed pursuits. She conceded that she lacked standing to assert an equal-protection claim based on the alleged racial profiling of the Kia suspect.

The court separately held that Frazier lacked standing to challenge alleged racial profiling of neighborhoods. Although she alleged an injury in fact, the court found that she had not shown that her injury was fairly traceable to the alleged neighborhood profiling. The complaint did not allege that Leneal lived in the neighborhood where he was killed, or in any other disproportionately Black neighborhood. The court characterized Frazier’s theory as asserting the equal-protection rights of the residents of the affected neighborhoods rather than Leneal’s own rights.

The court also ruled that, even if Frazier had standing, the race-discrimination claims would fail on the merits. The complaint did not define the neighborhoods or provide facts showing that disproportionately Black neighborhoods were similarly situated to predominantly white neighborhoods in relevant respects, such as crime rates. The court concluded that the complaint did not plausibly plead an equal-protection or Title VI violation and dismissed those claims without prejudice.

Wrongful-Death Claim and Disposition

After dismissing the claims over which it had original federal jurisdiction, the court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—over the wrongful-death claim. It dismissed that claim without prejudice.

Judge Schiltz’s order granted the City’s motion for judgment on the pleadings. The complaint was dismissed without prejudice, and judgment was ordered to be entered accordingly.