Elgersma v. City of St. Paul

Background

Three St. Paul police officers—Sergeant Lynette Cherry, Officer Christopher Hansen, and Sergeant Heather Weyker—went to Elgersma’s apartment building to arrest him under a probable-cause pickup order for a nonviolent felony. The officers did not have a warrant to enter his apartment. With help from the leasing manager and a maintenance worker, they arranged for the maintenance worker to lie about a water leak to persuade Elgersma to open his door.

Elgersma opened the door because of that deception. The officers then entered the apartment, did not identify themselves as police before entering, handcuffed Elgersma, searched him, and conducted a brief search of the apartment. The parties agreed that the officers lacked consent, an arrest warrant, and emergency circumstances that would justify the entry and arrest. Body-camera footage showed Elgersma standing several feet inside the apartment when the officers entered.

Elgersma brought claims under 42 U.S.C. § 1983, a federal civil-rights statute, alleging an unconstitutional search, entry, and arrest. He also brought Minnesota claims for battery, trespass, false arrest, and imprisonment. Elgersma sought partial summary judgment, which asks the court to rule that no genuine dispute of material fact requires a trial on particular issues. The defendants sought summary judgment on all claims, arguing that qualified immunity protected them from the federal claims and official immunity protected them from the state-law claims.

Federal constitutional claims

The court held that the arrest violated the Fourth Amendment. Although the law can permit a warrantless arrest begun in a public place, the court explained that the relevant Eighth Circuit decisions require the person to have come to the doorway voluntarily and without police deception or coercion. Elgersma opened his door only because the maintenance worker falsely reported a water leak. The court therefore concluded that the officers’ warrantless arrest inside the apartment was unlawful and that the unlawfulness was clearly established when it occurred.

Qualified immunity generally protects public officials from liability unless their conduct violated a clearly established right that a reasonable official would have known about. The court denied the officers qualified immunity because the undisputed facts showed both a constitutional violation and a clearly established right.

The court also found that the officers’ entry into the apartment was unlawful because they had no warrant, consent, or emergency circumstances. The search was likewise unconstitutional because it followed an unlawful arrest and therefore could not be justified as a search incident to a lawful arrest. The court denied the officers qualified immunity on the entry and search claims as well.

State-law claims

Under Minnesota law, official immunity can protect officials performing discretionary acts unless they act willfully or maliciously. The court determined that the officers were performing discretionary acts when they went to arrest Elgersma, but concluded that they were not entitled to official immunity. Applying Minnesota’s principally objective standard, the court found that the officers acted without legal reasonableness by violating clearly established law. The court also noted that two of the three officers, including the lead investigator, testified that they knew an entry into an apartment without consent, emergency circumstances, or a warrant was unlawful.

Disposition

Judge Katherine Menendez ordered that Elgersma’s partial motion for summary judgment was GRANTED and that the defendants’ motion for summary judgment was DENIED. The court stated that damages remained an open question.