Turner v. Eagan Police Department

Background

A Best Buy employee reported that an African American man had used a credit card belonging to a person described as being of “Asian descent.” Security footage later showed that Turner’s white female companion had used the card. Eagan police stopped Turner’s vehicle, arrested him, and Turner was charged with financial transaction card fraud. A Dakota County court later dismissed that charge, finding that the traffic stop lacked reasonable suspicion and that the charge lacked probable cause.

Turner brought claims under 42 U.S.C. § 1983, a statute allowing claims against persons acting under state authority for constitutional violations. He alleged violations of the Fourth and Eighth Amendments and alleged false imprisonment under 25 C.F.R. § 11.404. The City of Eagan, Eagan Police Department, and Best Buy moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which applies when a complaint does not state a legally sufficient claim.

Best Buy

The court dismissed Turner’s constitutional claims against Best Buy. Section 1983 generally applies only to state actors, but a private party may qualify if it willfully participates in joint activity with the government. Turner alleged that a Best Buy employee called police and made a report contradicted by security footage, but he did not allege facts showing concerted action between Best Buy and the police. The court also stated that the Fourth and Eighth Amendments generally limit government conduct, not the conduct of a private entity such as Best Buy.

The court also dismissed Turner’s false-imprisonment claim against Best Buy. Section 11.404 is a federal criminal regulation, and its text does not create a private right to sue. The court further concluded that, even if Turner’s claim were treated as a Minnesota common-law claim, he did not allege that Best Buy confined him.

Eagan Police Department

The court dismissed the claims against the Eagan Police Department because, under Minnesota law, the department is not a separate legal entity that can be sued.

City of Eagan

The court dismissed Turner’s Section 1983 claims against the City. A municipality cannot be held liable merely because its employees allegedly violated someone’s rights. Turner needed to allege that the conduct resulted from inadequate training, a city policy, or an unofficial city custom. Although he alleged that officers pulled him over, refused to answer his questions, removed him from his vehicle violently, left him outside in freezing conditions, and arrested him after viewing the video, he did not allege facts connecting that conduct to a city policy, custom, or inadequate training.

The court also dismissed the false-imprisonment claim against the City because Section 11.404 does not create a private cause of action. To the extent Turner intended to assert a Minnesota common-law claim, the court declined to exercise supplemental jurisdiction—authority to hear a related state-law claim after the federal claims are resolved—because it dismissed all of Turner’s federal claims.

Motion to Amend and Final Disposition

Turner’s motion stated that he wanted to dismiss his claims without prejudice if the court denied permission to amend, and the court construed it as a motion to amend. Because Turner did not amend within the period allowed as a matter of course after the motions to dismiss, he needed the opposing parties’ consent or the court’s permission. His motion did not include either a proposed amended complaint or a marked version showing the changes required by the local rule. The court therefore denied the motion to amend.

Judge Wilhelmina M. Wright ordered that the defendants’ motions to dismiss were granted, Turner’s motion to amend was denied, the complaint was dismissed without prejudice, and Turner’s motion for an extension of time was denied as moot.