Baker v. Holtz

Background

On February 4, 2025, Plaintiff Dean Lee Baker, Jr. filed this lawsuit under 42 U.S.C. § 1983 — a federal statute allowing individuals to sue state and local government officials for violations of constitutional rights — against Cody Alan Holtz, a Morrison County Sheriff's Office Deputy, and Morrison County. Baker alleged that on August 4, 2023, Deputy Holtz stopped his vehicle without probable cause or reasonable suspicion, in violation of the Fourth Amendment's protection against unreasonable seizures. Baker also brought a state-law claim for false arrest under Minnesota law, asserting that the subsequent arrest lacked a legal basis and that Morrison County was vicariously liable for Deputy Holtz's conduct.

Procedural History

Defendants filed an Answer on May 5, 2025, attaching body-camera and squad-car videos and other materials, and then moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). Defendants argued those materials showed the stop was lawful. Baker opposed the motion, challenging the authenticity and admissibility of the records and questioning whether such outside materials could be considered on a Rule 12 motion.

At a July 9, 2025 hearing, the court expressed skepticism about considering documents outside the pleadings on a Rule 12 motion but noted the documents raised serious questions about the viability of Baker's claims. The court converted the motion to one for summary judgment under Federal Rule of Civil Procedure 56, pursuant to Whatley v. Canadian Pac. Ry. Ltd., 904 F.3d 614 (8th Cir. 2018), and gave Baker several weeks to conduct limited discovery and either seek to dismiss the case or request a status conference.

On August 27, 2025, Baker's counsel informed the court by email that they did not intend to submit additional factual materials or argument, and subsequently filed a letter agreeing the motion could be decided as a summary-judgment motion on the existing record.

Legal Standard

Summary judgment — a ruling without a full trial — is appropriate when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). A fact is "material" only if its resolution could affect the outcome under governing law. A dispute is "genuine" only if a reasonable jury could return a verdict for the non-moving party. The court must view all inferences in the light most favorable to the non-moving party (here, Baker).

Analysis

Count One: Fourth Amendment Traffic Stop

A traffic stop is a "seizure" under the Fourth Amendment and is reasonable if supported by either probable cause of a traffic violation or a "reasonable articulable suspicion" of criminal activity — a standard lower than probable cause but requiring more than a hunch. Clinton v. Garrett, 49 F.4th 1132 (8th Cir. 2022). Under Minnesota law, driving with a suspended license is a misdemeanor. Minn. Stat. § 171.24, subd. 1.

Baker conceded that if Deputy Holtz had learned the registered owner had a suspended license before stopping the vehicle, that would supply reasonable articulable suspicion. The key factual dispute was whether the deputy actually ran the plate before initiating the stop.

The court found the evidence resolved that dispute in defendants' favor. BCA records showed Deputy Holtz queried the license plate at 9:21:37 p.m. and received a result showing "STATUS: SUSPENDED" at 9:21:39 p.m. The squad-car video showed the deputy was behind Baker's vehicle at 9:22 p.m. and initiated the stop just before 9:23 p.m. — after learning of the suspended license. Citing Kansas v. Glover, 589 U.S. 376 (2020), which holds that when an officer lacks information negating the inference that the owner is driving, a stop based on the owner's suspended license is reasonable, the court concluded Deputy Holtz had reasonable articulable suspicion.

The court also rejected Baker's authenticity challenges to the BCA records, noting that defendants had submitted certifying declarations with their reply brief, and that Baker had the opportunity to conduct additional discovery and submit further briefing but chose not to do so.

Summary judgment was granted to Deputy Holtz on the Fourth Amendment claim.

Count Two: State-Law False Arrest

Under Minnesota law, false arrest requires a showing that an arrest was made without proper legal authority; an arrest based on probable cause is lawful. Lundeen v. Renteria, 224 N.W.2d 132 (Minn. 1974).

Baker's only argument on the false-arrest claim was that the arrest was unlawful because it flowed from an unlawful stop. The court noted Baker did not separately argue that Deputy Holtz lacked probable cause to arrest him based on observations made during the stop (including signs of impairment and failed field sobriety tests). Because the court had already found the stop lawful, Baker's theory that the arrest was tainted by the stop necessarily failed. In a footnote, the court also stated that the record showed probable cause to make the arrest based on the deputy's own observations during the stop.

Summary judgment was granted to both defendants on the false-arrest claim.

Disposition

Defendants' Motion for Summary Judgment (converted from a motion for judgment on the pleadings) was granted. The matter was dismissed with prejudice — meaning Baker cannot refile the same claims in this court.