Smith v. Olmsted County Sheriff's Department

Background

Derrick Vonn Smith filed an amended complaint against the Olmsted County Sheriff’s Department, Deputy Schoenfelder, Richard Nerstad, Rochester Federal Medical Center, and Harris County Probation. Smith litigated without a lawyer and did not respond to the defendants’ motions to dismiss. The court nevertheless reviewed the motions’ legal and factual bases rather than granting them solely because Smith did not respond.

Smith alleged that, while he was being released from the federal medical center in Rochester, Minnesota, he was detained for several hours, strip-searched, and turned over to the Olmsted County Sheriff for extradition to Texas. He alleged that Deputy Schoenfelder violated his Fourth Amendment rights by arresting him on a defective fugitive warrant. He also alleged that detention in Olmsted County caused headaches because he did not receive previously used pain medication or his breathing inhaler, and that a rash was treated with foot cream. Smith sought $1 million in damages for pain and suffering, time away from his family and job search, incarceration during the COVID-19 pandemic, the strip search, and lost property.

Federal defendants

The court treated Smith’s claims against the federal defendants as official-capacity claims because the complaint did not say whether Richard Nerstad was sued personally or officially. The court also noted that Nerstad apparently had not been served in his individual capacity.

The court dismissed the official-capacity claims under Rule 12(b)(1), which permits dismissal when the court lacks authority to hear a case. First, the court held that 42 U.S.C. § 1983 applies only to state actors and therefore could not provide a claim against federal agencies or federal officials. Second, the court held that official-capacity constitutional claims seeking money damages are treated as claims against the United States, and the United States had not waived its legal immunity from those claims. The court concluded that it therefore lacked subject-matter jurisdiction over the claims against the federal defendants.

Olmsted County and Deputy Schoenfelder

The court held that the complaint did not state an official-capacity claim against Olmsted County or Deputy Schoenfelder. Because the complaint did not specify an individual-capacity claim against Schoenfelder, the court treated the claim as an official-capacity claim against the county. Such a claim requires allegations that a county policy, official decision, or established custom caused the constitutional violation. The court found that Smith alleged wrongdoing by the defendants but did not allege that the conduct resulted from an Olmsted County policy or custom.

The court also rejected Smith’s Fourth Amendment claim against Schoenfelder. It explained that Minnesota law permits a peace officer to make a warrantless arrest based on reasonable information that a person is charged in another state with a crime punishable by more than one year in prison. Schoenfelder had received an active Texas arrest warrant concerning Smith’s probation violation following a felony drug conviction. A Minnesota judge found probable cause and ordered Smith held pending further proceedings. The court concluded that Schoenfelder did not violate Smith’s Fourth Amendment rights by arresting and detaining him.

The court separately concluded that Smith could not establish a clearly established constitutional violation based on the Texas governor’s delegation of signature authority. The delegation occurred after Schoenfelder arrested Smith, and the court stated that Schoenfelder was not responsible for that later event. The court also noted that Minnesota law and precedent accept extradition requests signed by an authenticating officer on behalf of another state’s governor.

As to Smith’s medical-care allegations, the court applied the standard for deliberate indifference to serious medical needs under the Eighth Amendment. It found that the complaint did not allege that the headaches or rash were objectively serious. It also found that Smith did not allege telling anyone about his headaches and did not allege that the treatment for his rash failed to relieve his symptoms. The court further stated that Smith had no constitutional right to soft water or to choose his medical treatment.

Harris County Probation

The court granted Harris County Probation’s motion under Rule 12(b)(2), which allows dismissal when the court lacks personal jurisdiction over a defendant. Smith’s only allegation against the office was that it placed him on fugitive status after he failed to appear for probation because he had been arrested by federal officials.

The court found that Harris County Probation had no contacts with Minnesota, that the complaint did not connect its alleged conduct to Minnesota, and that the operative events described in the complaint occurred in Minnesota rather than Harris County, Texas. It therefore concluded that exercising personal jurisdiction over Harris County Probation would violate due-process limits on the court’s power over an out-of-state defendant.

Order

The court granted the Olmsted County Sheriff’s Department and Deputy Schoenfelder’s motion to dismiss, granted Harris County Probation’s motion to dismiss under Rule 12(b)(2), and granted the federal defendants’ motion to dismiss official-capacity claims. Judge Michael J. Davis ordered that all claims be dismissed without prejudice and directed that judgment be entered.