Sinclair v. Culbeaux

Background

On November 1, 2024, Minnesota State Patrol Trooper Gustavo Culbeaux observed Kenya Lenee Sinclair's vehicle speeding on Interstate 35W and activated his emergency lights to initiate a traffic stop. The vehicle did not pull over for approximately two minutes. Trooper Culbeaux then executed a PIT (Pursuit Intervention Technique) maneuver—bumping the rear passenger side of Sinclair's vehicle twice—which brought the vehicle to a stop on an exit ramp without striking any barriers or other vehicles.

After the vehicle stopped, Sinclair exited and refused Trooper Culbeaux's commands to turn around and be handcuffed, stating he lacked "jurisdiction" over her. A second trooper arrived about one minute later, and Sinclair was handcuffed. Sinclair informed Trooper Culbeaux that her grandson was in the backseat; troopers retrieved the child, medics evaluated him, and the child's mother arrived approximately 29 minutes later to take custody. Sinclair was transported to the county jail, where her handcuffs were removed upon arrival after she agreed not to resist.

Sinclair, proceeding pro se (without an attorney), filed suit on June 6, 2025, asserting: (1) a Section 1983 claim for Fourth Amendment excessive force and unlawful seizure; (2) a Section 1983 claim for Fourteenth Amendment substantive due process violation based on separation from her grandchild; (3) an ADA Title II claim for failure to provide reasonable accommodations for her physical and mental disabilities; (4) state-law battery; (5) state-law negligence; and (6) state-law intentional infliction of emotional distress. She sought damages, injunctive relief against Minnesota State Patrol practices, and declaratory relief.

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1) (lack of subject-matter jurisdiction) and Rule 12(b)(6) (failure to state a claim). The court also considered squad car and body camera video footage, which it treated as "necessarily embraced by the pleadings" and therefore properly considered on a motion to dismiss. Where the video contradicted Sinclair's complaint allegations—such as her claim that Trooper Culbeaux struck her vehicle despite her having stopped, or that troopers refused to help notify the child's mother—the court declined to accept those allegations as true.

Sovereign Immunity (Eleventh Amendment)

The court dismissed all claims against the State of Minnesota, the Minnesota State Patrol, and Trooper Culbeaux in his official capacity for damages. The Eleventh Amendment bars private suits against states and their arms (such as the Minnesota State Patrol) in federal court, regardless of whether the plaintiff seeks monetary or equitable relief. Official-capacity damages claims against state employees are treated as claims against the state itself and are equally barred.

Neither recognized exception to Eleventh Amendment immunity applied. Congress has not abrogated (eliminated) sovereign immunity for Section 1983 claims, and Minnesota has not consented to such suits. The sovereign immunity bar also extended to Sinclair's pendent state-law claims, which arose from the same conduct. For Sinclair's ADA claims, Title II abrogates sovereign immunity only when the conduct implicates access to judicial services or rises to the level of unconstitutional conduct; neither condition was met here. Sinclair also did not argue that the abrogation was "congruent and proportionate" to the specific harm—an alternative route to overcoming immunity—so those ADA claims were also barred.

Injunctive and Declaratory Relief

The Ex parte Young doctrine permits suits for prospective (forward-looking) injunctive relief against state officers in their official capacity without triggering Eleventh Amendment immunity. However, the court found that Sinclair's complaint did not allege any ongoing violation of federal law—all of her alleged injuries arose from a single past event (her November 2024 arrest). Because Ex parte Young does not apply to remediate past violations, and because declaratory relief similarly requires anticipation of future conduct rather than adjudication of past wrongs, the court dismissed Sinclair's requests for injunctive and declaratory relief. The court also noted that injunctive relief against Trooper Culbeaux in his individual capacity is not available because individual-capacity defendants lack the authority to provide the requested institutional relief.

Section 1983 — Fourth Amendment Excessive Force

PIT Maneuver

Trooper Culbeaux asserted qualified immunity. Qualified immunity shields government officials from liability unless they violated a "clearly established" constitutional right—meaning the right's contours were so definite that any reasonable official would have known the conduct was unlawful.

The court found that the right to be free from a PIT maneuver under these circumstances was not clearly established, relying heavily on Moore-Jones v. Quick, 909 F.3d 983 (8th Cir. 2018). In that case, the Eighth Circuit held that an officer was entitled to qualified immunity for executing a PIT maneuver after a driver refused to stop for approximately 51 seconds following activation of emergency lights. Here, Sinclair continued driving for approximately two minutes—longer than the driver in Moore-Jones—and Trooper Culbeaux struck her vehicle on the passenger side on a low-traffic exit ramp, mirroring the care taken in Moore-Jones. Sinclair's argument, raised only in her opposition brief (not in her complaint), that she was looking for a safer location to stop was not considered because a plaintiff cannot amend a complaint through a brief opposing dismissal. Even if considered, the court held that officers need not divine a suspect's subjective motivations for not complying with a stop command.

Use of Handcuffs

To prove excessive force from handcuffing, a plaintiff must allege "something more" than the de minimis (minimal) force inherent in applying handcuffs. The court found that Sinclair's complaint never alleged that she was handcuffed, and she did not allege any resulting injury. Without factual allegations of force applied or injury suffered, this theory of excessive force failed.

Section 1983 — Fourteenth Amendment Due Process (Family Integrity)

Sinclair alleged that the separation from her grandchild during the arrest violated her substantive due process right to family integrity. The court identified several independent grounds for dismissal.

First, the constitutional right to family integrity recognized by the Supreme Court in Troxel v. Granville, 530 U.S. 57 (2000), belongs to parents, not grandparents. Courts have generally declined to extend that right to grandparents, and the Eighth Circuit has stated in dicta that grandparents likely lack such rights when grandchildren are in their parents' custody. Sinclair did not allege that she had custody of, or lived with, her grandchild, so she did not fall within the narrower category of custodial grandparents whom some courts have recognized as potentially having such rights.

Second, even assuming Sinclair had a cognizable right, she failed to plausibly allege a violation. The roughly 29-minute separation was necessitated by her arrest and her inability to care for the child at that moment; troopers and medics supervised the child and contacted his mother throughout. The court noted that courts have rejected due process claims involving far lengthier separations, including removal of children for two weeks and nearly two years during abuse investigations.

ADA Claim Against Trooper Culbeaux Individually

Title II of the ADA prohibits discrimination by a "public entity," a term that does not encompass individual employees. The Eighth Circuit has squarely held that Title II claims cannot be brought against public employees in their individual capacities. This claim was therefore dismissed as a matter of law.

State-Law Claims

The remaining claims—battery, negligence, and intentional infliction of emotional distress against Trooper Culbeaux individually—were dismissed without prejudice. Under 28 U.S.C. § 1367(c)(3), a district court may decline supplemental jurisdiction over state-law claims when all federal claims have been dismissed. Because all federal claims were dismissed well before trial, the court found the standard factors (judicial economy, convenience, fairness, and comity) pointed toward declining jurisdiction, and dismissed the state-law claims without prejudice so they may be considered by Minnesota state courts.

Miscellaneous Rulings

Sinclair filed a second application to proceed without prepaying fees, which the court denied as moot because her first such application had already been granted. Sinclair also filed a motion for postconviction relief related to her state criminal prosecution, which the court denied for lack of jurisdiction over her state criminal case, noting that the motion appeared to have been intended for the Ramsey County District Court.

Disposition

Defendants' Motion to Dismiss was granted in its entirety. The complaint was dismissed without prejudice. Sinclair's second fee-waiver application was denied as moot. Sinclair's motion for postconviction relief was denied.