Lee v. Coopers Corner Liquor

Background

Abraham Sigurd Lee brought a civil-rights action against Coopers Corner Liquor, two of its employees, and the Anoka County Sheriff’s Office. Lee alleged that the business’s owner and employees racially profiled him by making false and unsubstantiated accusations based on his race. The complaint appeared to connect those accusations to a criminal matter involving telephone harassment or threats that Lee was allegedly blamed for because of mistaken voice identification. The complaint also vaguely alleged that the business used law enforcement. Lee sought $2,500,000 for alleged constitutional and state-law violations.

Legal Standard

The court applied the rule requiring a complaint to provide enough factual information to make a claim legally plausible, rather than merely possible. Although courts read complaints filed without a lawyer generously, a plaintiff must still allege facts supporting the claims.

Analysis

The Anoka County Sheriff’s Office argued that it could not be sued because a county sheriff’s department is not a legal entity. The court agreed. It also concluded that, even if the Sheriff’s Office could be sued, Lee had not plausibly alleged any connection between the office and a violation of his civil rights. The complaint did not describe what involvement, if any, the office had in the alleged conduct.

As to Coopers Corner Liquor and its employees, the court explained that constitutional claims generally require conduct by government actors. A private person or business may be treated as a government actor only in circumstances making the conduct fairly attributable to the government. The complaint did not allege a connection between the business or its employees and government action. In addition, the complaint did not identify when the alleged conduct occurred, the circumstances surrounding it, the person who made each accusation, what the accusations concerned, or what consequences Lee suffered.

The court also addressed Lee’s citations to Minnesota statutes concerning identity theft and falsely reporting a crime. It concluded that private citizens cannot enforce criminal statutes through a private lawsuit, so those citations did not state claims for relief.

Disposition

Judge Wilhelmina M. Wright granted defendants’ motions to dismiss, Docket Nos. 18 and 26, and dismissed Lee’s complaint without prejudice for failure to state a claim on which relief can be granted. The order directed that judgment be entered.