Phillips v. City of Minneapolis, The

Background

Ronald Lawrence Phillips sued The City of Minneapolis in June 2021. His complaint asserted claims involving the Americans with Disabilities Act (ADA), “loss of familia,” loss of public stature, taxi regulations, and false arrest. Phillips attached documents concerning a proposed license-plate revocation, a parking citation, a City claim form, and a letter from the United States Department of Justice approving a payment claim under a settlement with Wells Fargo and Company concerning Title III of the ADA.

Minneapolis moved to dismiss the complaint for failure to state a claim under Rule 12(b)(6). The court noted that a complaint must include enough factual allegations to make a claim legally plausible, rather than relying only on labels, conclusions, or a formulaic statement of legal requirements.

ADA claim

Minneapolis argued that Phillips failed to state a claim under Title II of the ADA. The court explained that such a claim requires allegations that the plaintiff is a qualified individual with a disability, was excluded from or denied the benefits of a public entity’s services, programs, or activities, or was otherwise discriminated against, and that the exclusion, denial, or discrimination occurred because of the disability.

The court found that Phillips’s complaint alleged no facts supporting these elements. The Department of Justice letter about a settlement involving Wells Fargo and Title III of the ADA did not provide information about a possible Title II violation by Minneapolis. The court therefore granted Minneapolis’s motion to dismiss as to the ADA claim.

Loss of public stature

The court construed Phillips’s allegation of “loss of public stature” as a defamation claim under Minnesota common law. Such a claim requires allegations that Minneapolis made a false and defamatory statement about Phillips, published it without a privilege to a third party, and harmed his reputation in the community.

The court found that Phillips’s complaint alleged no facts supporting any element of defamation. It therefore granted Minneapolis’s motion to dismiss as to this claim.

Taxi regulations

Phillips referred to Minneapolis’s regulation of taxi licenses or services and attached a copy of his taxi-driver license. The court analyzed whether he had standing, meaning a legally sufficient personal injury connected to the defendant’s conduct that a favorable court decision could likely remedy.

The court found that Phillips did not identify a particular taxi regulation or allege facts explaining how Minneapolis’s regulations injured him. It therefore concluded that he had not established standing to challenge the taxi regulations and granted Minneapolis’s motion to dismiss as to that claim.

False arrest

Under Minnesota law, a false-arrest claim requires allegations that Minneapolis arrested Phillips and that the arrest was unlawful. The court found that Phillips did not allege facts supporting his vague assertion that Minneapolis unlawfully arrested him. The court therefore granted Minneapolis’s motion to dismiss as to the false-arrest claim.

The court stated that it was unable to find legal authority supporting “loss of familia” and did not address that claim because Phillips did not further explain it.

Disposition

Judge Wilhelmina M. Wright granted The City of Minneapolis’s motion to dismiss. The order dismissed Phillips’s complaint without prejudice and directed that judgment be entered accordingly.