Crabtree v. Clearwater County Sheriffs Office

Background

Brian Crabtree filed a complaint against the Clearwater County Sheriffs Office, Larry Olson, and Travis Iverson. The complaint alleged that Olson took Crabtree’s truck in the winter of 2020, a prosecutor charged him with robbery and later dropped the charges, Iverson falsely said that Crabtree assaulted him, and a county dismissed a fifth-degree possession charge. The complaint also suggested that Crabtree sought relief from Roseau County.

In later filings, Crabtree provided additional information. He alleged that the Sheriff’s Office arrested him for aggravated robbery on November 19, 2019, that the case was dismissed, and that Iverson slandered him when the arrest was reported in the news. He also alleged that Olson and the Sheriff’s Office seized and impounded his truck without a search warrant in December 2020. Crabtree said he spent 90 days in jail before the charges were dismissed and that, because he lost use of his truck, he could not get to work and lost his job and truck.

Report and recommendation

A magistrate judge recommended dismissing Crabtree’s complaint without prejudice for failure to state a claim. The recommendation also advised denying as moot Crabtree’s application to proceed without prepaying fees or costs. Crabtree filed objections.

Because Crabtree was representing himself, the court read his objections liberally. The court concluded that the objections were not specific enough for a fresh legal review of the disputed issues. It therefore reviewed the recommendation for clear error and found none.

Ruling

Judge Wilhelmina M. Wright overruled Crabtree’s objections and adopted the magistrate judge’s report and recommendation. The court dismissed Crabtree’s complaint without prejudice for failure to state a claim. It denied Crabtree’s application to proceed without prepaying fees or costs as moot. The opinion text does not provide the recommendation’s detailed explanation for why the complaint failed to state a claim.