Putmon v. City of Minneapolis
- Katherine Menendez
- 0:22-cv-01369
- U.S. District Court · District of Minnesota
- 3
In Putmon v. City of Minneapolis, Judge Menendez granted Regenscheid’s dismissal motion, allowed amendment, and ordered a filing schedule because the complaint lacked sufficient facts.
Tyler Putmon and Tyler Regenscheid: the ruling concerned Putmon’s two claims against Regenscheid; Putmon received leave to amend, and counsel for all parties was ordered to submit a case schedule.
What happened
Putmon v. City of Minneapolis concerned Tyler Putmon’s claims against Tyler Regenscheid over Putmon’s arrest. Putmon asserted a federal false-arrest claim and a state-law false-imprisonment claim.
The court found that the amended complaint provided too few facts to plausibly support the claims or to evaluate Regenscheid’s immunity defenses. The complaint alleged that Putmon attended a protest as an independent journalist, wore a vest marked “press,” and was arrested without probable cause or arguable probable cause.
Judge Katherine Menendez granted Regenscheid’s motion to dismiss, granted Putmon leave to amend, and ordered counsel for all parties to submit a schedule for the amended complaint and later filings. The court did not decide whether Regenscheid had qualified or official immunity.
The detailed version
- Putmon v. City of Minneapolis · No. 0:22-cv-01369
- Katherine Menendez
- Aug. 4, 2022
Background
Tyler Putmon brought two claims against Tyler Regenscheid for Regenscheid’s role in Putmon’s arrest: a false-arrest claim under 42 U.S.C. § 1983 and a state-law false-imprisonment claim. Regenscheid moved to dismiss, arguing that qualified immunity and official immunity protected him. The court held a hearing on July 26, 2022, and granted the motion from the bench.
Court’s analysis
The court applied the standard for a motion to dismiss for failure to state a claim. A complaint must include enough factual allegations to make relief plausible, rather than merely stating labels, conclusions, or the elements of a claim. The court generally accepts factual allegations as true and draws reasonable inferences for the plaintiff, but it does not accept wholly conclusory allegations or legal conclusions as facts.
The court declined to decide whether Regenscheid was entitled to qualified or official immunity. It concluded that the First Amended Complaint did not allege enough facts for the court even to begin the qualified-immunity analysis. The complaint effectively alleged only that Putmon attended a protest as an independent journalist, wore a vest stating “press” in large letters, and was arrested without probable cause or arguable probable cause. The court held that these allegations were insufficient both to state a plausible claim for relief and to determine whether Regenscheid was entitled to qualified immunity based on the complaint.
Regenscheid relied entirely on a police report he had authored and submitted with his motion. The court held that, at the pleading stage, it could not consider the report for the truth of the matters it asserted.
Order
The court granted Regenscheid’s Motion to Dismiss. It also granted Putmon leave to amend the First Amended Complaint under Federal Rule of Civil Procedure 15(a)(2). Finally, it ordered counsel for all parties to submit, by August 16, 2022, a stipulation governing the schedule for the amended complaint and subsequent filings. The order does not state whether the claims were dismissed with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.