Loyd v. Schmitt
Minnie Loyd v. Jason Schmitt, in his individual and official capacities; and City of Minneapolis
- Laura Provinzino
- 0:24-cv-01391
- U.S. District Court · District of Minnesota
- 19
In Loyd v. Schmitt, Judge Provinzino granted summary judgment for defendants, dismissing with prejudice all Fourth Amendment claims against a Minneapolis police officer and the City.
Individuals whose vehicles or phones are named in law enforcement search warrant applications but who are not themselves the target of the underlying criminal investigation. This opinion addresses the circumstances under which template-based or copy-and-paste errors in warrant applications can give rise to Fourth Amendment liability, and clarifies that an unexecuted warrant alone does not constitute a search.
What happened
In Loyd v. Schmitt (Case No. 24-cv-1391), plaintiff Minnie Loyd sued Minneapolis Police Officer Jason Schmitt and the City of Minneapolis, claiming that Officer Schmitt violated her Fourth Amendment rights by including false statements in several search warrant applications related to a 2019 drug investigation targeting a man named Kevin Green. The warrants at issue involved tracking devices on two cars registered to Loyd (a Porsche and an Audi) and phone-tracking warrants for two cell phones. Loyd sought money damages, a court declaration that the conduct was unconstitutional, and an order requiring the City to improve its training on warrant applications.
The court found that Loyd's requests for injunctive and declaratory relief had to be dismissed because those remedies can only address ongoing or future harm, not past injuries — and all of the alleged misconduct occurred in 2019 and was finished. On the core Fourth Amendment claims, the court found no genuine factual dispute supporting a violation for any of the four warrants. The inaccuracies in the phone-tracking warrants were the product of copy-and-paste errors and template oversights, which amount to innocent mistakes or negligence rather than deliberate or reckless falsehoods. The Porsche warrant was never executed, meaning no actual search occurred. The Audi warrant contained no false statements at all.
Judge Provinzino granted Defendants' motion for summary judgment on all claims and dismissed Loyd's complaint with prejudice, meaning she cannot refile the same claims. The Monell claim against the City — which alleged the City had a policy, custom, or training failure that caused the constitutional violations — was also dismissed because such a claim can only succeed if an individual officer first committed a constitutional violation, and no such violation was found here. Loyd did not respond to the summary judgment motion, the court's show-cause order, or participate meaningfully in discovery.
The detailed version
- Loyd v. Schmitt · No. 0:24-cv-01391
- Laura M. Provinzino
- Feb. 17, 2026
Background
Officer Jason Schmitt of the Minneapolis Police Department was investigating weapons, violent crime, and narcotics in 2019. Based on a tip from an arrested individual, he identified Kevin Green as a large-scale heroin dealer who drove a rose-colored Porsche registered to plaintiff Minnie Loyd. Over the course of the investigation, Officer Schmitt obtained several search warrants: (1) a tracker warrant for Loyd's Porsche (never executed); (2) a tracking warrant and extension for a phone number ending in 1225 (the "1225 phone," associated with Green); (3) a tracking warrant for a phone number ending in 9886 (the "9886 phone"); and (4) a tracker warrant for an Audi registered to Loyd (successfully executed).
The phone-tracking warrants contained inaccurate statements. The 1225 phone warrant and its extension included a boilerplate line stating that both a confidential reliable informant (CRI) and a confidential informant (CI) had previously provided reliable information — a statement that was false and carried over from a law enforcement template. The 9886 phone warrant contained three additional inaccuracies: (1) that a confidential informant identified the 9886 phone as associated with Green (caused by a find-and-replace-all function in Microsoft Word that unintentionally swapped phone numbers); (2) that a court order was already in place on the 9886 phone and expiring (an inadvertent holdover from the prior warrant extension); and (3) that the 9886 phone was used to rent a Maserati on June 10, 2019 (based on information from a car rental agency that later proved incorrect).
Green was ultimately convicted of federal narcotics offenses and sentenced to 180 months in prison. During his federal criminal proceedings, a Franks hearing was held — a proceeding, established by Franks v. Delaware, 438 U.S. 154 (1978), to determine whether a warrant was based on deliberate or reckless falsehoods — before U.S. Magistrate Judge Elizabeth Cowan Wright. Magistrate Judge Wright recommended denial of most suppression motions, finding that probable cause existed for the warrants even after removing the admitted inaccuracies. The presiding district judge largely adopted those recommendations.
Loyd filed this Section 1983 lawsuit — a civil rights lawsuit brought under 42 U.S.C. § 1983, which allows individuals to sue state or local officials for constitutional violations — on April 17, 2024. She alleged that Officer Schmitt's use of false statements in the warrant applications violated her Fourth Amendment rights. She also brought a Monell claim against the City of Minneapolis, asserting that the City's policies, customs, or failure to train caused the alleged violations. Loyd sought money damages, a declaratory judgment, and injunctive relief requiring improved officer training on warrant applications.
After filing, Loyd and her counsel largely ceased participating in the litigation. She did not provide required initial disclosures, did not seek any discovery, did not respond to Defendants' motion for summary judgment, and did not respond to the court's show-cause order.
Legal Standards
Summary judgment is appropriate when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law. Where a party fails to respond to an opposing party's factual assertions, those facts may be treated as undisputed.
A Fourth Amendment violation based on a warrant affidavit requires proof that the officer deliberately or recklessly included false statements. Innocent mistakes or negligence are insufficient. Even where deliberate or reckless falsehoods are proven, no Fourth Amendment violation occurs if the remaining content of the warrant affidavit still establishes probable cause — the legal standard requiring a reasonable basis to believe that evidence of a crime will be found.
Analysis
I. Lack of Standing for Injunctive and Declaratory Relief
The court dismissed Loyd's requests for injunctive and declaratory relief because both remedies are prospective — they address future or ongoing harm, not past wrongs. All of the alleged unconstitutional conduct occurred in 2019 during a concluded criminal investigation. Loyd's own complaint described the alleged injuries entirely in the past tense. There was no evidence of any ongoing or imminent injury. The court also noted that to the extent Loyd sought relief on behalf of other people not party to the lawsuit, she lacked standing (the legal right to bring a claim) to do so.
II. Section 1983 Claim Against Officer Schmitt Individually
1225 Phone Warrants
The court found no evidence that the 1225 phone belonged to Loyd, which would undercut any reasonable expectation of privacy she might assert in that phone. Even assuming she had such an expectation, the court found that the inaccurate CRI/CI statement in the warrant was a template holdover that Officer Schmitt mistakenly failed to delete — an innocent mistake, not a deliberate or reckless falsehood. The same applied to the extension warrant, which was drafted using the original as a template.
9886 Phone Warrant
The court addressed each of the four challenged statements: - The inaccurate statement that a confidential informant identified the 9886 phone as linked to Green was caused by the find-and-replace-all function in Word, which unintentionally changed the phone number throughout the document. Officer Schmitt did not notice the error until the federal prosecutor pointed it out. The court found this was negligence at most. - The statement that a court order was in place on the 9886 phone was an inadvertent holdover from the 1225 phone extension warrant used as a template — again, innocent mistake or negligence. - The statement that the 9886 phone was used to rent a Maserati was based on information from a car rental agency at the time, which Officer Schmitt reasonably relied on. That the information later proved incorrect does not establish a deliberate or reckless falsehood under Franks. - The statement that Green was "rarely observed without Loyd being present" was not shown to be false. The only evidence Loyd offered was that she was not with Green during a single traffic stop on April 19, 2019, which does not contradict a general observation about their frequent association.
Furthermore, even if all the inaccuracies were treated as deliberate falsehoods, Magistrate Judge Wright had already concluded in the Franks proceedings during Green's case that probable cause still existed for the 9886 phone warrant after removing those statements. Loyd offered no evidence or argument to the contrary.
Porsche Warrant
The tracker warrant for the Porsche was never executed and no GPS device was ever placed on the vehicle. The Fourth Amendment protects against unreasonable searches and seizures, not against the mere issuance of a warrant. Because no search actually occurred, Loyd suffered no Fourth Amendment injury from this warrant.
Audi Warrant
Loyd's complaint did not identify any false statements in the Audi warrant application, and the record contained none. Green's own suppression motion in his federal case did not claim false statements in the Audi warrant. Without a false statement, no Franks-based Fourth Amendment claim is possible.
The court therefore dismissed the Section 1983 claim against Officer Schmitt in his individual capacity.
III. Official Capacity Claim and Monell Claim Against the City
A Section 1983 damages claim against Officer Schmitt in his official capacity is treated as a claim directly against the City itself, analyzed under the Monell framework. Under Monell v. Department of Social Services of New York, 436 U.S. 658 (1978), a municipality can only be held liable for a constitutional violation if that violation resulted from an official policy, an unofficial custom, or a deliberate failure to train or supervise employees. Critically, municipal liability cannot attach unless an underlying constitutional violation by an individual officer is first established. Because the court found no constitutional violation by Officer Schmitt, the Monell claim against the City was also dismissed.
Disposition
Defendants' motion for summary judgment was granted in full. Loyd's complaint was dismissed with prejudice — meaning she may not refile the same claims.
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.