Jackson v. City of Brooklyn Center

Background

Edell Jackson sued the City of Brooklyn Center and Brooklyn Center Police Officers Jake Wilkins, Stephen Pastor, Joel Iverson, Cooper Gauldin, Ryan Soliday, and Kate Deering under 42 U.S.C. § 1983. He alleged that officers unconstitutionally apprehended and arrested him on January 14, 2021. According to Jackson’s complaint, officers blocked and rammed his truck, repeatedly used tasers, tackled and struck him, and used a taser while he was on the ground. He also alleged that officers planted a firearm in his jacket and that the Brooklyn Center Police Department and City had policies, customs, or training practices that caused excessive force.

Jackson asserted Fourth Amendment claims for unreasonable seizure and excessive force, claims against the City under Monell v. Department of Social Services and City of Canton v. Harris, and state-law claims for battery, negligence, and negligent infliction of emotional distress. The opinion states that the claims against the Hennepin County Sheriff’s Department defendants had already been dismissed by stipulation and that a separate procedural-due-process claim had also been dismissed with prejudice.

The defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), applying the same standard as a motion to dismiss for failure to state a claim under Rule 12(b)(6). The court accepted Jackson’s allegations as true except where authenticated body-camera and squad-car videos completely contradicted them. The court also considered certain public records from Jackson’s related federal criminal case.

Rulings on the Individual Officers’ Federal Claims

The court applied qualified immunity, which generally protects government officials from damages unless their conduct violated a constitutional right that was clearly established at the time.

For Officer Soliday’s use of his squad car against Jackson’s truck, the court found that officers had information that Jackson was suspected of a violent domestic assault involving a firearm, was believed to possess two guns, had an active warrant for fleeing police, and was attempting to drive away. The court found that the video showed Soliday traveling at 11 miles per hour and contradicted Jackson’s allegation that Soliday’s impact propelled the truck into a snowbank. The court concluded that Soliday’s conduct was objectively reasonable and did not violate a clearly established right. Soliday was therefore entitled to qualified immunity.

For Sergeant Pastor and Officer Gauldin’s use of tasers near the truck, the court found that the videos showed Jackson moving away from officers and ignoring commands while officers believed he was armed and dangerous and had fled from them. The court concluded that the tasings were not objectively unreasonable and that Jackson’s claimed right to be free from taser use in those circumstances was not clearly established. Pastor and Gauldin were therefore entitled to qualified immunity.

For Officer Gauldin’s takedown, the court found that Jackson was actively moving away from officers after the tasers failed to stop him. The court concluded that taking him to the ground was not objectively unreasonable and that Jackson had not identified sufficiently similar authority clearly establishing that the takedown violated the Fourth Amendment. Gauldin was therefore entitled to qualified immunity.

For the alleged strikes by Officers Gauldin and Iverson and Officer Wilkins’s use of a taser in drive-stun mode, the court found that the videos showed Jackson continuing to struggle while officers tried to handcuff him. The court concluded that the strikes and taser use were reasonable efforts to subdue an actively resisting suspect whom officers believed was armed, involved in a violent assault, and a flight risk. The court also found that the officers’ conduct did not violate clearly established law. Pastor and Gauldin were entitled to qualified immunity for the strikes, and Wilkins was entitled to qualified immunity for the drive-stun taser use.

Claims Against Officer Deering

Jackson did not oppose dismissing Officer Deering. The court granted the defendants’ motion in that respect and dismissed Deering from the action with prejudice.

Claims Against the City

The court dismissed Jackson’s Monell claim, which alleged that a City policy or custom caused the constitutional violations. Because the court found no constitutional violation by the officers, it held that the City could not be liable on that theory. The court also found that the prior incidents Jackson identified were not sufficiently similar to the encounter at issue and did not establish a widespread, persistent pattern of unconstitutional conduct. The court granted the City’s motion as to Count 3 and dismissed that count.

The court also dismissed Jackson’s City of Canton failure-to-train claim. It found no underlying constitutional violation by a City employee and found that Jackson had not adequately alleged a pattern of similar conduct showing deliberate indifference. The court granted the City’s motion as to Count 4 and dismissed that count.

State-Law Claims

Jackson brought state-law claims for battery, negligence, and negligent infliction of emotional distress. The court held that the officers’ responses to the dispatch and arrest involved discretionary decisions made under tense and uncertain circumstances. Applying Minnesota’s official-immunity doctrine, the court found that the officers’ conduct was objectively legally reasonable and that Jackson’s allegations of malice were insufficient. The court dismissed Claims 5, 6, and 7 against the officers.

The court also applied vicarious official immunity to the City because the state-law claims against the City were based on conduct by officers who were entitled to official immunity. The court dismissed Claims 5, 6, and 7 against the City. It did not address the defendants’ alternative arguments that the state-law claims failed on their merits.

Disposition

Judge Susan Richard Nelson granted the Brooklyn Center defendants’ motion for judgment on the pleadings. The order states that the matter was dismissed with prejudice and directed that judgment be entered. The court concluded that repleading would not cure the deficiencies in Jackson’s Second Amended Complaint.