Minor v. Yahye Mahmed Ahmed

Background

On September 12, 2023, Plaintiff Randall Midge Minor, II, was riding a light-rail train in St. Paul, Minnesota. Minor observed two men fighting at the other end of the train and intervened; he bearhugged one man (wearing a green shirt) to separate them. The man in green was eventually pushed off the train onto the platform by another passenger. Minor, standing in the train doorway, shoved the man in green and then exited the train and ran toward him.

Officer Yahye Mahmed Ahmed, a defendant sued in his individual capacity, was on duty patrolling the platform. Ahmed witnessed Minor punching the man in green. During a pause in the fight, Ahmed believed the men were about to resume fighting and deployed chemical spray on both men without announcing his presence or warning that spray would be used. The man in green told Ahmed that others were trying to fight him and had tried to pull him off the train.

Minor returned to the train. Ahmed re-entered through a different door, ordered Minor to "come here," and placed his left hand on Minor's shoulder to guide him toward the door. Minor immediately shoved Ahmed and became physically combative. Ahmed pushed Minor onto the laps of seated passengers. Minor then pushed Ahmed across the aisle onto other passengers. A second officer helped Ahmed up. Ahmed drew his Taser, issued two verbal commands for Minor to get on his stomach — which Minor did not obey — and then used the Taser in drive-stun mode once, causing Minor to fall to the floor. Ahmed handcuffed Minor and removed him from the train.

Ahmed testified that he could not hear what other passengers were saying during the incident. Minor claims he could not see due to the chemical spray and believed he was defending himself. The court reviewed body-worn camera footage, three train car videos, and deposition testimony from both Minor and Ahmed.

Minor filed this action on January 9, 2025, asserting: (1) unlawful seizure and arrest; (2) excessive force; (3) false arrest and imprisonment; and (4) assault. Defendants — Ahmed and the Metropolitan Council — moved for summary judgment on all claims.

Legal Standard

Summary judgment (a ruling in a party's favor without a trial) is appropriate when there are no disputed issues of material fact and the moving party is entitled to judgment as a matter of law under Federal Rule of Civil Procedure 56(a). The court views all evidence and reasonable inferences in the light most favorable to the non-moving party (here, Minor). The non-moving party must point to specific facts in the record creating a genuine dispute for trial; mere allegations are insufficient.

Federal Claims — Qualified Immunity

Qualified immunity is a legal doctrine that protects government officials from personal civil liability when their conduct does not violate a clearly established constitutional or statutory right that a reasonable person would have known about. To overcome qualified immunity, a plaintiff must show: (1) the facts, viewed favorably to the plaintiff, show a deprivation of a constitutional or statutory right; and (2) that right was clearly established at the time of the alleged deprivation. The court may address either prong first.

Unlawful Seizure / Arrest

A warrantless arrest does not violate the Fourth Amendment (which protects against unreasonable searches and seizures) if supported by probable cause — i.e., facts sufficient to lead a reasonable person to believe that the suspect has committed or is committing an offense. An officer also receives qualified immunity if "arguable probable cause" exists, meaning the officer's mistaken belief in probable cause was objectively reasonable.

The court found that Ahmed had at least arguable probable cause. He witnessed Minor punching the man in green, and the man in green told Ahmed that others had been fighting him. Although other passengers indicated the man in green was the original aggressor, Ahmed testified he could not hear them, and even if he could, he had still witnessed Minor punching the man. Additionally, Minor's subsequent physical resistance to being detained independently gave Ahmed probable cause to believe Minor was committing the offense of resisting. The court held that Ahmed is entitled to qualified immunity on the unlawful arrest claim.

Excessive Force — Chemical Spray

Excessive force claims arising during an arrest are analyzed under the Fourth Amendment using a balancing test that weighs the nature of the intrusion against the government's interests, accounting for: the severity of the crime, whether the suspect poses an immediate threat, and whether the suspect is actively resisting or attempting to flee. The analysis is objective and based on the perspective of a reasonable officer at the scene.

Minor argued that Ahmed's failure to announce his presence or warn before deploying chemical spray made the use of force unreasonable, and that Ahmed knew Minor was defending himself. The court rejected this. At the moment Ahmed deployed the spray, he had only witnessed Minor punching the other man and believed the fight was about to resume. The court distinguished cases requiring fair warning before pepper spray use, finding those cases involved nonviolent or non-resisting individuals — unlike Minor, whom Ahmed reasonably believed was violent and posed a threat to others. No reasonable juror could find Ahmed's deployment of chemical spray objectively unreasonable.

Excessive Force — Taser

Minor argued that Taser use was excessive because he was non-threatening, non-fleeing, and non-resisting at the time. He relied on Jackson v. Stair, 944 F.3d 704 (8th Cir. 2019), and Villebrun v. Nienaber, No. 24-cv-504, 2026 WL 800044 (D. Minn. Mar. 23, 2026), both involving suspects who were not physically resisting when tased. The court found those cases distinguishable: Minor had punched another man, shoved Ahmed, and shoved Ahmed onto other passengers. After a second officer helped Ahmed up, Ahmed issued two commands to get on his stomach, which Minor ignored. Ahmed used the Taser only once. The court found no reasonable juror could conclude the single Taser use was objectively unreasonable.

Clearly Established Prong

Even if factual disputes existed as to whether Ahmed's conduct was unconstitutional, the court held that Ahmed would still be entitled to qualified immunity because the specific rights allegedly violated were not clearly established. As of September 2023, it was not clearly established that an officer violates constitutional rights by: (1) using chemical spray to break up a violent interaction between two men; (2) using a Taser once to control a physically resisting arrestee; or (3) arresting someone after witnessing him punch another person and resist detention. Ahmed is entitled to qualified immunity on this independent basis as well.

State-Law Claims — Official Immunity

Under Minnesota law, public officials are immune from tort liability for discretionary acts unless those acts constitute a "willful or malicious wrong" — meaning the official intentionally performed a wrongful act without legal justification or willfully violated a known right of the plaintiff. The parties agreed that Ahmed's use of force and arrest decisions were discretionary. The court therefore moved to the malice inquiry.

The malice standard involves both subjective and objective elements, but the Minnesota Supreme Court has explained it relies primarily on the objective inquiry into whether the official had reason to believe the act was prohibited. The court found the record insufficient to support a finding of malice or bad faith. Minor pointed to comments Ahmed made two years after the incident, after viewing the video and learning the man in green had started a separate fight on the train. The court held that an officer's post-hoc reflection that he might have handled things differently does not establish that his actions at the time were malicious or unreasonable. Because no reasonable jury could find that Ahmed acted with malicious intent or bad faith, Ahmed is entitled to official immunity on the state-law false arrest and assault claims.

Because Ahmed is entitled to official immunity, the Metropolitan Council is also entitled to immunity under the doctrine of respondeat superior (the legal principle that an employer can share in an employee's immunity). The court noted that Minor did not assert Monell liability (a theory under which local governments can be sued directly for unconstitutional policies or customs) against the Metropolitan Council.

Disposition

The court granted Defendants' motion for summary judgment in its entirety. All of Minor's claims were dismissed with prejudice.