Spottswood v. Washington County

Background

Shawn Clarke Spottswood sued Washington County, Minnesota. His amended complaint concerned the county’s investigation and prosecution of him for possessing tools for burglary or theft. The opinion states that a jury convicted him in March 2017, but the state court later granted his motion for a judgment of acquittal.

Spottswood alleged that Deputy Sara Peulen made false statements in a report used to justify an unlawful search and seizure, and that a prosecutor identified as Wedes continued prosecuting him despite allegedly knowing about those statements. He claimed violations of the Fourth and Eighth Amendments. He also alleged that, after his acquittal, an unidentified corrections officer required him to clean his jail cell before leaving, which he claimed violated the Thirteenth Amendment. In addition, he asserted a claim for compensation under Minnesota Statutes section 611.362 and sought $3.25 million in damages, along with additional compensation related to attending college.

Referral and permission to proceed without paying fees

Spottswood asked the court to refer him to the Federal Bar Association’s Pro Se Project while he sought legal assistance. The court explained that it had discretion to request an attorney for a person proceeding without a lawyer in a civil-rights case. After considering the complaint and Spottswood’s repeated difficulties addressing whether individuals were being sued personally or in their official roles, the court granted the referral request. It stated that a volunteer lawyer might agree to meet with or represent Spottswood, but that no lawyer was required to do so and no appointment was made by the order.

The court also granted Spottswood’s application to proceed without prepaying filing fees because it found that he qualified financially. The court directed the Clerk of Court not to take service-related action at that time because the court might need to screen a future amended complaint.

Problems identified in the amended complaint

The court ordered Spottswood to file a second amended complaint within 30 days. The new pleading had to be labeled “Second Amended Complaint,” comply with the basic pleading rules, clearly state the factual and legal grounds for each claim, and specify the capacity in which any individual defendant was being sued for claims under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state or local actors for constitutional violations.

The amended complaint named Washington County but also discussed Peulen, Wedes, and an unidentified corrections officer. The court said it would assume, for purposes of construing the complaint liberally, that Spottswood intended to name those individuals. But the complaint did not specify whether they were sued in their individual capacities, official capacities, or both. Under the Eighth Circuit’s default rule, the court stated that such claims would be treated as official-capacity claims only.

The court further explained that the claims would effectively be claims against Washington County because the potential individual defendants worked for the County. A local government is not automatically responsible for employees’ conduct under § 1983. To state an official-capacity claim against the County, Spottswood would need to allege that a County policy, custom, or failure to train caused the constitutional violations. The court found that the amended complaint described employees’ conduct but did not identify any County policy, custom, or failure to train.

Potential disposition if no further amendment was filed

The order did not dismiss the amended complaint. Instead, it stated that if Spottswood failed to file an adequate second amended complaint, the court would treat the existing amended complaint as the operative pleading and issue a report and recommendation. Based on the problems discussed, the court said it would likely recommend dismissal of the constitutional claims without prejudice. It also said it would likely recommend declining supplemental jurisdiction—the court’s authority to hear related state-law claims—over the Minnesota compensation claim and recommend dismissal of that claim without prejudice for lack of subject-matter jurisdiction.

The court also noted a possible question under the Rooker-Feldman doctrine, which can prevent a federal district court from reviewing a state-court judgment. It said that, because the issue appeared uncertain and the claims as pleaded would likely fail for other reasons, it was comfortable bypassing that issue if no second amended complaint was filed.

Order

The court granted the referral request, granted the application to proceed without prepaying fees or costs, and ordered Spottswood to submit a second amended complaint meeting the stated conditions within 30 days. The order did not enter a final dismissal.