Larson v. Sanner

Background

The order addresses two cases brought by Ryan M. Larson. They arose from Larson’s arrest after Cold Spring Police Officer Tom Decker was shot and killed in a bar parking lot on November 29, 2012. Police entered Larson’s rented room, arrested him, and held him in the Stearns County Jail for five days before releasing him. Law enforcement stated that there was probable cause for the initial arrest but not for continued detention. Police later determined that Eric Thomes was likely the shooter.

Larson alleged that defendants unlawfully entered his apartment, searched and destroyed his property, falsely arrested and maliciously prosecuted him, defamed him, and retaliated against him. He also sought to hold Stearns County responsible for the individual defendants’ conduct.

Summary judgment

Summary judgment is a decision entered without a trial when there is no genuine dispute over a material fact and the moving party is entitled to judgment under the law. Defendants asserted qualified immunity and absolute immunity and sought summary judgment on all claims.

The court explained that qualified immunity generally protects public officials from civil damages unless their conduct violated a constitutional or statutory right that was clearly established at the time. The court concluded that defendants’ entry into Larson’s apartment and the later arrest, searches, and detention complied with the Fourth Amendment. It also concluded that Larson had not established that defendants’ statements to the press violated his constitutional rights.

The court separately ruled that Larson’s claims against Stearns County Attorney Janelle Kendall were barred by absolute prosecutorial immunity, or otherwise by qualified immunity. The court found that Kendall was acting as an officer of the court when she approved search-warrant applications and sought to extend Larson’s detention. Larson also failed to show that Kendall’s media statements violated his constitutional rights.

The court additionally stated that Larson’s First Amendment retaliation claim was unfounded. According to the order, defendants did not return Larson’s firearms because his felony record barred him from possessing firearms under Minnesota law; they released his felony juvenile records because the records were public information; and they cleared his name. The court said Larson provided no evidence supporting retaliation.

The court granted defendants’ motions for summary judgment. The conclusion states that Larson’s claims were dismissed with prejudice.

Expert testimony

Defendants also moved to exclude testimony from Larson’s expert witness, Chris Anderson, under the rule governing expert evidence. Anderson managed clients’ online reputations, searched for Larson on the internet, and concluded that Larson’s online reputation had been damaged. His report estimated that he could repair the damage for $1,530,000.

The court granted the motion to exclude Anderson’s testimony. It found that Anderson’s internet-search method was not scientific or testable because search results vary based on browsing history and other factors. The court also found that a jury could understand how to conduct an internet search without Anderson’s testimony. The court did not consider another expert report Larson submitted at the hearing.

Other motion and disposition

Although Larson labeled one filing a motion for summary judgment, the court determined that it was actually a request for another stay and declined to grant that request. The order’s conclusion states that Larson’s motion for summary judgment was denied. Judge Paul A. Magnuson ordered that judgment be entered.