Samaha v. The City of Minneapolis

Background

The plaintiffs, several Minneapolis residents who alleged that they participated peacefully in protests following George Floyd’s death, sued The City of Minneapolis, Minneapolis Chief of Police Medaria Arradondo, and unidentified officers. They alleged that Minneapolis Police Department officers used tear gas, pepper spray, rubber bullets, flashbangs, and other less-lethal munitions against peaceful protesters, sometimes without warnings or orders to disperse. The plaintiffs brought claims under 42 U.S.C. § 1983, a federal law that allows people to sue state or local officials for violating constitutional rights. They asserted violations of the First, Fourth, and Fourteenth Amendments and sought declaratory and injunctive relief for themselves and two proposed classes.

The City Defendants moved to dismiss. They argued that the complaint did not adequately plead municipal liability under Monell v. Department of Social Services, which requires a constitutional violation to result from a city policy, custom, or deliberately indifferent failure to train or supervise. They also argued that the claims against Arradondo in his individual capacity were not adequately pleaded, that the plaintiffs lacked standing to seek future relief, and that the proposed class allegations should be stricken.

Court’s Analysis

The court applied the standard for a motion to dismiss for failure to state a claim. At this stage, it accepted well-pleaded factual allegations as true, viewed them in the plaintiffs’ favor, and considered whether the complaint alleged enough facts to make relief reasonably plausible.

Municipal-liability claim

The court held that the plaintiffs plausibly alleged an unofficial city custom of using excessive force against peaceful protesters. The complaint described similar alleged conduct on different days from May 26 through May 31, 2020, in several locations, involving many officers and numerous protesters. The court concluded that these allegations were sufficient at the pleading stage to support an inference of a continuing, widespread, and persistent pattern of unconstitutional force.

The court also found that the plaintiffs plausibly alleged that city policymakers knew about the conduct and either deliberately ignored it or tacitly authorized it. Although the allegations about the policymakers’ deliberate choice were limited, the court found that the widespread reporting of the protests and the city’s own description of the unrest supported allowing the claim to continue. The court declined to address the plaintiffs’ alternative municipal-liability theories based on an official policy or failure to train or supervise because the unofficial-custom theory was adequately pleaded.

Claims against Arradondo individually

The court dismissed the claims against Arradondo in his individual capacity without prejudice. It found that the plaintiffs had not plausibly alleged that Arradondo directly authorized the force used against them. The complaint instead alleged that a state-led coordinating center directed the broader response and that on-scene commanders gave blanket authorizations under the Minneapolis Police Department’s policies at the time.

The court also found that the plaintiffs did not allege specific facts showing Arradondo’s personal involvement in training or supervising the unidentified officers. His general responsibility as chief of police, and alleged awareness of the officers’ conduct, were not enough by themselves to establish individual supervisory liability under § 1983.

Standing to seek future relief

The court rejected the City Defendants’ standing challenge. Standing is the requirement that a plaintiff show an actual injury, a connection between the injury and the defendant’s conduct, and a likelihood that a favorable court decision will remedy the injury. The court found that the plaintiffs plausibly alleged a likelihood of future injury because they said they intended to protest peacefully again in Minneapolis and alleged that the police department had a pattern or practice of using excessive force against peaceful protesters.

Class allegations

The court denied the request to strike the class allegations. It found that the proposed classes’ claims plausibly shared legal and factual issues, that the named plaintiffs’ claims were plausibly typical of the proposed class members’ claims, and that the requested injunctive relief could apply to the proposed classes. The court emphasized that the case was at the pleading stage, before discovery and before a formal decision on class certification.

Disposition

The court granted in part and denied in part the City Defendants’ Motion to Dismiss. It dismissed the plaintiffs’ claims against Arradondo in his individual capacity without prejudice. It denied the motion as to the municipal-liability claim, standing to seek prospective relief, and the class allegations. Judge Susan Richard Nelson signed the order on March 11, 2021.