Lozoya v. City of Cloquet

Background

Clarence Lozoya was arrested by Cloquet police officer Scott Beckman on December 5, 2016, and charged with assault offenses. He pleaded guilty to felony second-degree assault on January 4, 2017, and was sentenced to four years in prison. The opinion states that Lozoya did not allege he was innocent of the charge to which he pleaded guilty.

Before Lozoya’s plea, Carlton County Attorney Thomas H. Pertler had received information about alleged misconduct by Beckman in another matter. Lozoya alleged that this information was impeachment evidence—evidence that could be used to challenge Beckman’s credibility—and that it was not disclosed to him or his attorneys before he pleaded guilty. In 2019, after Lozoya’s attorney learned of the alleged misconduct, the state criminal case was dismissed with prejudice, Lozoya was released from prison, and his record was expunged.

Lozoya sued under 42 U.S.C. § 1983, a federal civil-rights statute, and Minnesota tort law. His claims included deprivation of liberty and false imprisonment, municipal liability under Monell, intentional infliction of emotional distress, negligent supervision, aiding and abetting torts, and injunctive relief. His claims against Beckman individually had previously been dismissed without prejudice by stipulation.

Motions and governing standard

Carlton County moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The City of Cloquet and Carey Ferrell moved under Rules 12(b)(6) and 12(c), the latter being a motion for judgment on the pleadings. The court applied the same basic standard to both motions: it accepted the complaint’s factual allegations as true and drew reasonable inferences in Lozoya’s favor, but required facts making relief plausible rather than speculative.

While the motions were pending, Lozoya moved for leave to amend. The court granted that motion because the proposed changes were minor and did not add issues the defendants had not already addressed. The court treated the proposed amended complaint as the operative pleading.

Federal claims

The court determined that all of Lozoya’s federal claims rested on one alleged constitutional violation: the defendants’ failure to provide impeachment information about Beckman before Lozoya pleaded guilty. The court relied on the Supreme Court’s decision in United States v. Ruiz, which held that the Constitution does not require the government to disclose material impeachment evidence before entering a plea agreement with a criminal defendant.

Because Lozoya’s federal claims depended on a constitutional duty that the court concluded did not exist in this context, the court held that he could not plead plausible § 1983 claims, including his municipal-liability claims. The court also rejected Lozoya’s argument that the County Attorney had admitted a constitutional violation when the state criminal case was dismissed.

The court explained that the record did not show what issue the state court had decided when it allowed Lozoya to withdraw his plea and dismissed the criminal case. The state court’s written reasoning was not in the record, and the County Attorney’s dismissal request referred only to correcting a “manifest injustice.” The court found that this phrase could refer to multiple issues and did not establish that the state court had determined that a Brady or Giglio constitutional violation occurred. The court also rejected Lozoya’s arguments based on issue preclusion, claim preclusion, and waiver.

State-law claims and disposition

After dismissing every federal claim, the court declined to exercise supplemental jurisdiction over the remaining Minnesota state-law claims. It stated that considerations of judicial economy, convenience, fairness, and comity usually favor declining jurisdiction in that situation. The court therefore dismissed the state-law claims without prejudice to Lozoya’s right to refile them in Minnesota state court.

The court’s order was as follows:

- Lozoya’s motion for leave to amend the complaint was GRANTED. - The defendants’ motions to dismiss were GRANTED. - Lozoya’s § 1983 claims—identified in the order as Claims 1, 4, and 7—were dismissed with prejudice. - Claim 7, labeled “Injunctive Relief,” was not treated as a standalone claim; to the extent it derived from the § 1983 claims, it was dismissed with prejudice. - Lozoya’s state-law claims—Claims 2, 3, 5, and 6—were dismissed without prejudice.

Judge Eric C. Tostrud directed that judgment be entered accordingly.