Standberry v. Ramsey County

Background

Deputies Steven Eddicus and Joe Stradinger responded to a medical call involving Nekeya Tamara Moody. Moody was experiencing a mental-health crisis, resisted being handcuffed, and made movements that Eddicus interpreted as reaching for his service weapon. The deputies initially restrained her, placed her on her side, and later moved her onto her stomach to handcuff her.

Moody stopped moving and became quiet before the deputies finished handcuffing her. After she had stopped resisting, Stradinger placed pressure on her upper back with his knee and hand while she was handcuffed and lying face down. The deputies later moved her onto her side and waited for paramedics. The paramedics eventually found no pulse and began resuscitation. Moody regained a pulse but died four days later.

Standberry sued Ramsey County, Eddicus, and Stradinger. The claims alleged excessive force, deliberately indifferent policies and training, deliberate indifference to a serious medical need, negligence, and wrongful death.

Expert testimony

The court granted the defendants’ motion to exclude Dr. Ronald K. Wright’s testimony. Under Federal Rule of Evidence 702, expert testimony must be relevant and reliable. The court found that Wright’s one-page report did not explain the reasoning or methodology supporting his opinions that Moody’s death involved asphyxia and that she suffered asphyxiation during the arrest. The court also found that the report did not satisfy the expert-disclosure requirements of Federal Rule of Civil Procedure 26(a), and that the failure was not substantially justified or harmless under Rule 37(c).

Summary judgment

Summary judgment is appropriate when no genuine dispute of material fact requires a trial and the moving party is entitled to judgment as a matter of law. The court viewed the evidence in the light most favorable to Standberry except where the undisputed video evidence blatantly contradicted her version of events.

Counts 1 and 2: excessive force

The court analyzed the deputies’ individual liability under the Fourth Amendment and qualified immunity. Qualified immunity generally protects government officials from damages unless their conduct violated a federal right that was clearly established at the time.

The court held that Eddicus was entitled to qualified immunity on Count 1. It found that the deputies’ initial use of force to restrain Moody was objectively reasonable because she was resisting, appeared to pose some risk to herself or others, and made movements that could reasonably be understood as reaching toward Eddicus’s service weapon.

The court reached a different result for Stradinger on Count 2. It held that applying pressure to Moody’s back while she was handcuffed, lying face down, and no longer resisting was not objectively reasonable. The court also held that the right to be free from that use of force was clearly established. It therefore denied summary judgment on Count 2, leaving the claim against Stradinger for further proceedings.

Count 3: Ramsey County policies and training

Standberry acknowledged that she lacked sufficient evidence to support her claim against Ramsey County based on its policies, practices, customs, training, and supervision. The court granted summary judgment on Count 3 and dismissed that claim with prejudice.

Count 4: deliberate indifference to a serious medical need

The court found evidence that Moody had an objectively serious medical need. She was in distress during a mental-health crisis, became unresponsive after the use of force, and had a rapid pulse and slow breathing.

The court also found a factual question about whether Eddicus and Stradinger knew of and deliberately disregarded that need. The deputies knew Moody was unresponsive and observed signs including a rapid pulse and slow breathing, but they did not tell the paramedics about those signs, the force used, or the earlier prone restraint. The court also relied on the Ramsey County Sheriff’s Office policy requiring deputies to provide medical personnel with information about force used and possible medical risks. The court denied qualified immunity to Eddicus and Stradinger on this claim.

The court granted summary judgment to Ramsey County on Count 4 because the county could not be held vicariously liable for its employees’ conduct and Standberry had not established a sufficient county-policy claim. Count 4 remains against Eddicus and Stradinger.

Count 5: negligence and wrongful death

The court applied Minnesota’s official-immunity doctrine, which generally protects public officials from liability for discretionary acts unless they act willfully or maliciously. It found that the deputies’ conduct was discretionary.

The court held that Eddicus was entitled to official immunity on Count 5. It held that Stradinger was not entitled to official immunity because a reasonable jury could find that his objectively unreasonable pressure on Moody’s back was malicious under the applicable standard. Ramsey County was not entitled to official immunity under respondeat superior.

The court dismissed with prejudice any negligence theory within the wrongful-death claim. Count 5 remains against Ramsey County and Stradinger solely on the underlying wrong of excessive force, not negligence. The court granted summary judgment to Eddicus on Count 5.

Order

The court granted the motion to exclude Dr. Wright’s expert testimony. It granted in part and denied in part the defendants’ motion for summary judgment: granted as to Counts 1 and 3; denied as to Count 2; granted to Ramsey County on Count 4, which remains against Eddicus and Stradinger; and granted to Eddicus on Count 5, which remains against Ramsey County and Stradinger solely based on excessive force. Counts 1 and 3 were dismissed with prejudice. Judge Donovan W. Frank also directed the Clerk of Court to correct the plaintiff’s party text to identify Standberry as trustee for the next of kin of Nekeya Tamara Moody.