Harris v. Maplewood Police Department

Background

Anthony Harris, representing himself, sued the Maplewood Police Department and John Doe, identified as the arresting officer, under Section 1983. That law allows a person to seek relief for a constitutional violation committed by someone acting under state law. Harris alleged that officers arrested him without probable cause, used excessive force, and racially profiled him.

On February 16, 2015, Harris went to a Maplewood Menards store and used a $2,535.79 check to buy appliances. Store employees connected Harris to a security alert about suspicious or fraudulent checks and confirmed with the bank that the check was bad. Police officers then arrested Harris at the store, handcuffed him, searched him, read him his rights, and took him to the Ramsey County Law Enforcement Center, where he was booked and released pending further investigation.

The defendants moved for summary judgment, which asks whether the evidence requires a trial or instead requires judgment as a matter of law. Harris did not respond to the motion.

Police Department

The court ruled that the claims against the Maplewood Police Department had to be dismissed because a municipal police department is not a suable legal entity. The court added that even if Harris had properly sued the City of Maplewood, dismissal would still be warranted because he had not shown a genuine dispute of material fact concerning probable cause, excessive force, or racial profiling.

Probable Cause

The court explained that a warrantless arrest violates the Constitution when the arresting officers lack probable cause. Probable cause exists when the known facts would lead a reasonably cautious officer to believe that the person had committed or was committing an offense.

The court found that the defendants submitted undisputed evidence supporting probable cause. Menards employees identified Harris as the person described in a security alert, reported that the check he used was bad, and provided police with records of other bad checks connected to Harris. Because Harris presented no evidence creating a genuine factual dispute, the court granted summary judgment on his claim that he was arrested without probable cause.

Excessive Force

Harris alleged that officers approached him with weapons drawn, ordered him to the ground, placed a knee or foot on him, restricted his breathing, and caused pain while handcuffing him. The officers denied using force, and the court reviewed store surveillance video of the arrest.

The court found that the video showed the officers approaching without drawn weapons, Harris immediately complying with their instructions, and the officers handcuffing, searching, and escorting him away. The video did not show the officers using force or forcing Harris to the ground. Because Harris did not provide evidence creating a genuine dispute about the force used, the court granted summary judgment on the excessive-force claim.

Racial Profiling

Harris also claimed that his arrest violated the Equal Protection Clause because it was based on racial profiling. The court stated that such a claim generally requires evidence that similarly situated people were not stopped or arrested. Harris presented no such evidence, so the court ruled that this claim failed on the merits.

The court separately addressed the racial-profiling theory under the Fourth Amendment. It ruled that an officer’s personal motive does not invalidate an arrest supported by probable cause. Because the court had found probable cause, it granted summary judgment on this claim as well.

Disposition

Judge Michael J. Davis granted the defendants’ motion for summary judgment. The court dismissed Harris’s complaint, all claims stated in it, and all claims that could have been asserted, including claims against the John Doe officers and other specified associated persons or entities, in their entirety, with prejudice and on the merits. The court directed that judgment be entered.