McReynolds v. State of Minnesota

Background

Barry Ishmael McReynolds alleged that Minnesota State Trooper Zachary Hansen stopped him during a snowy night in December 2019 because snow made the license plate on his 2002 GMC Yukon unreadable. Hansen then performed a pat-down search and field sobriety tests after believing he smelled alcohol and suspecting McReynolds might have been drinking. McReynolds alleged that he did not test as intoxicated. He was charged with driving after suspension and driving with a snow-covered license plate, but those charges were later dropped.

Claims

McReynolds asserted constitutional claims under the First, Fourth, Fifth, and Fourteenth Amendments through 42 U.S.C. § 1983, a federal law allowing claims for violations of constitutional rights by state actors. He brought those claims against the State of Minnesota, Hansen, and Troopers Doe 1–6, including claims against the individual troopers in both their individual and official capacities. He also asserted a claim against the State under Monell v. Department of Social Services of the City of New York, and Minnesota-law assault claims against Hansen and the State.

Motion and response

The defendants filed a partial motion to dismiss Counts 1, 2, and 3 as asserted against the State and against the troopers in their official capacities, and Count 5, the assault claim against the State. The defendants stated that McReynolds had agreed to dismiss the specified claims in Counts 1, 2, and 3. McReynolds opposed only dismissal of Count 5, but he filed no response to the motion by the deadline or afterward.

Court’s reasoning

The court accepted the defendants’ representation about McReynolds’s agreement because it was signed by counsel and McReynolds had not indicated that it was inaccurate. The court therefore dismissed the specified portions of Counts 1, 2, and 3.

As to Count 5, the court said McReynolds’s failure to respond constituted a waiver and independently could support granting the motion. The court also concluded that the Eleventh Amendment barred federal-court jurisdiction over the Minnesota-law assault claim against the State because the State was the real party in interest and had not consented to the suit. The opinion stated that no reasonable basis for Count 5 was apparent.

Order and effect

The court GRANTED the defendants’ Partial Motion to Dismiss. Counts 1, 2, and 3 were DISMISSED WITHOUT PREJUDICE to the extent asserted against the State of Minnesota and to the extent asserted against the individual defendants in their official capacities. Count 5 was DISMISSED WITHOUT PREJUDICE. The court canceled the May 22, 2023 hearing. The order did not dismiss the remaining claims described in the partial motion’s disposition.