Groschen v. Kopel

Background

On August 18, 2024, Woodbury Police Department Officer Alana Kopel stopped Steven Groschen's vehicle because it lacked appropriate registration or license plates. Groschen refused to provide identification or insurance information, asserting he had not committed a crime. When Officer Robin Kivel arrived, Groschen continued to refuse. Kopel then arrested Groschen and officers searched his person incident to the arrest. Groschen was subsequently charged in Washington County District Court with failure to possess or display a driver's license, failure to carry proof of insurance, and failure to display vehicle registration. All charges were ultimately dismissed by the City pursuant to a plea agreement.

Groschen, self-represented and self-identified as a sovereign citizen, filed an Amended Complaint against Kopel and Kivel individually. The court construed his constitutional claims as arising under 42 U.S.C. § 1983 (the federal civil rights statute that allows individuals to sue state or local officials for violating their constitutional rights). He also invoked 18 U.S.C. § 242, a federal criminal statute prohibiting deprivation of civil rights under color of law. Groschen sought more than $2 million in compensatory and special damages.

Legal Standard

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. Under this standard, the court accepts all factual allegations in the complaint as true and asks whether the complaint states a claim that is "plausible on its face." The court draws all reasonable inferences in favor of the plaintiff but is not required to accept legal conclusions framed as factual allegations.

Fourteenth Amendment — Right to Travel

Groschen argued that the Fourteenth Amendment guarantees an absolute right to travel using an automobile, and that state vehicle licensing and registration laws apply only to commercial actors, not private individuals. The court rejected this premise outright, citing a consistent body of case law from the Eighth Circuit Court of Appeals and Minnesota district courts, including multiple decisions specifically rejecting sovereign-citizen arguments of this type. The court held that state laws requiring display of license plates, vehicle registration, proof of insurance, and other licensing requirements do not unduly impinge on any constitutional right to travel. Because the Amended Complaint failed to allege facts establishing a viable Fourteenth Amendment claim—let alone a "clearly established" constitutional right—the qualified immunity doctrine (which protects government officials from civil liability unless they violated a clearly established right a reasonable person would have known about) shielded the officers. This claim was dismissed with prejudice.

Fourth Amendment — Search and Seizure

Groschen alleged that the officers violated his Fourth Amendment right against unreasonable searches and seizures by searching his person at arrest and seizing his personal property. The court found these allegations were purely conclusory—mere legal labels unsupported by factual detail. Critically, the Amended Complaint did not identify what property was seized, nor did it allege facts explaining why the search or seizure was unreasonable. Without such facts, the court could not draw a reasonable inference of liability. The court also noted in a footnote that even if the allegations could be read as challenging the reasonableness of the arrest itself, such a claim would fail because the Fourth Amendment permits warrantless arrests based on probable cause even for minor offenses, and Groschen did not allege facts negating probable cause. Because the deficiency was one of insufficient factual pleading rather than a legally foreclosed theory, this claim was dismissed without prejudice.

18 U.S.C. § 242 — Federal Criminal Statute

Groschen alleged the officers violated 18 U.S.C. § 242, which is a federal criminal law prohibiting deprivation of rights under color of law. The court dismissed this claim because § 242 is a criminal statute that only the United States government, acting as prosecutor, can enforce. Private individuals have no right to bring a civil lawsuit under § 242. Groschen offered no response to this argument. This claim was dismissed with prejudice.

Disposition

Judge Bryan granted the defendants' motion to dismiss in full: 1. Groschen's Fourteenth Amendment claim and his claim under 18 U.S.C. § 242 are dismissed with prejudice (barring refiling). 2. Groschen's Fourth Amendment claim is dismissed without prejudice (potentially allowing refiling with additional factual detail).

The court directed that judgment be entered accordingly.