Parada v. Anoka County

Background

Myriam Parada was arrested by Coon Rapids police officer Nicolas Oman after a July 2017 car accident. Parada acknowledged that she had been driving without a license. She provided her address, proof of insurance, and a Mexican government identification card. Oman could not verify her identity through Minnesota’s driver-record system or dispatch, although Parada’s stepfather later arrived, identified her, and provided information corroborating her identity and address. Oman nevertheless arrested her for driving without a license.

Oman took Parada to the Anoka County Jail for processing and release with a citation. Jail records showed that she was marked ready for release at about 9:36 p.m., but she remained in custody. A jail employee contacted Immigration and Customs Enforcement (ICE) after Parada reported that she was born in Mexico and was a United States citizen. ICE later requested that the jail hold her and arrived at about 1:23 a.m. to take her into custody. The opinion states that the jail had an unwritten policy requiring employees to contact ICE whenever a foreign-born person was detained, regardless of citizenship or immigration status, and that the jail attempted to wait for ICE before beginning release procedures for foreign-born detainees.

Parada asserted claims under the Fourth and Fourteenth Amendments through 42 U.S.C. § 1983, the Minnesota Constitution, and Minnesota common law. The parties filed cross-motions for summary judgment. Summary judgment is a decision without a trial when no genuine dispute about a fact could affect the result and the law entitles one side to judgment.

Officer Oman’s Motion

The court granted in part and denied in part Officer Oman’s motion for summary judgment. It granted summary judgment on Parada’s Fourth Amendment claim and her common-law false-imprisonment claim, Counts I and VIII. The court held that Oman had probable cause to arrest Parada for driving without a valid license. It also held that Parada had not shown that Oman unreasonably prolonged the traffic stop. The court explained that Minnesota’s rule generally requiring citation rather than arrest for misdemeanors did not change the Fourth Amendment’s probable-cause standard.

The court denied summary judgment on Parada’s Fourteenth Amendment Equal Protection Clause claim, Count IV. Parada presented evidence that Oman had not arrested six non-Hispanic people he encountered driving without licenses, that she had supplied information corroborating her identity, and that Oman had made anti-immigrant or anti-Hispanic social-media posts. The court concluded that a reasonable jury could find that Oman selectively enforced the law because of Parada’s race, national origin, or alienage. The court also rejected Oman’s qualified-immunity argument and denied summary judgment concerning punitive damages to the extent it depended on the remaining constitutional claim.

Anoka County and Sheriff Stuart

The court granted in part and denied in part Anoka County and Sheriff James Stuart’s motion for summary judgment. It granted summary judgment on Count I, the Fourth Amendment claim, because Parada’s arrest was constitutionally reasonable and her continued detention could not be treated as a second arrest under the Fourth Amendment. It also granted summary judgment on Counts II and III, the Fourteenth Amendment substantive- and procedural-due-process claims, because the court found that Parada had affirmatively abandoned those claims by stating in amended complaints that they were included only to preserve them for appeal. The court granted summary judgment to the John and Jane Doe defendants on all counts.

On Count V, Parada’s Fourteenth Amendment equal-protection claim concerning the jail’s policy, the court granted Parada’s motion for partial summary judgment as to Anoka County. The court held that the policy facially discriminated based on national origin and was not narrowly tailored to further a compelling government interest. The court stated that damages remained to be decided at trial. The court denied Parada’s motion as to Sheriff Stuart and denied Stuart’s motion because a genuine dispute remained about whether he was entitled to qualified immunity. The dispute included whether Stuart was involved in continuing to apply or interpret the policy and whether he was deliberately indifferent to its unconstitutional effects.

The court denied Anoka County’s motion for summary judgment on Counts VI, VII, VIII, X, and XI, involving Minnesota constitutional claims, false imprisonment, declaratory relief, and injunctive relief. The court found a genuine factual dispute about whether county deputies delayed Parada’s release because of their interactions with ICE and because she was foreign-born. The court denied the motion as to Sheriff Stuart on Counts V through XI, as stated in the order.

Other Defendants and Expert Testimony

The court granted the Coon Rapids Defendants’ motion for summary judgment as to the City of Coon Rapids on all counts. It granted the motion as to Officer Oman on Counts I, VI, VII, and VIII, and denied it as to Officer Oman on Counts IV and IX.

The court denied the Coon Rapids Defendants’ motion to exclude Parada’s expert testimony as moot because the court had already granted Oman summary judgment on the Fourth Amendment claim to which one expert’s testimony appeared to relate. The court noted that the defendants could renew the motion if Parada planned to use that testimony on her remaining Fourteenth Amendment claim.

Disposition

The order granted and denied the parties’ summary-judgment motions in part as specified above. The equal-protection claims involving Oman and the Anoka County jail policy, along with other claims against Anoka County and Sheriff Stuart, were not resolved in the defendants’ favor at summary judgment.