Crow v. Rasmussen

Background

Johnny James Crow brought two claims against Minneapolis police officers Eric Lee Rasmussen and Andrew Timothy Ruden and The City of Minneapolis. Count One alleged that the defendants violated his Fourth and Fourteenth Amendment rights through excessive force and unlawful arrest under 42 U.S.C. § 1983, a federal civil-rights statute. Count Two alleged false arrest under Minnesota law.

On November 9, 2022, Rasmussen and Ruden stopped Crow at a Minneapolis gas station after their patrol-car system showed that his vehicle was connected to Narcisse Redkettle. The system reported that Redkettle had an active warrant for a drug offense, described him as a wanted person, warned that he was combative, and listed “Johnny James Crow” as one of Redkettle’s aliases. The officers ordered Crow out of his vehicle, handcuffed him, searched him for weapons, and placed him in the patrol car while checking his identification. Crow remained handcuffed for less than three minutes, was in the patrol car for less than two minutes, and was released after the officers determined that he was not Redkettle. The entire encounter lasted less than five minutes.

Materials Considered

The court considered the officers’ body-camera videos and the incident detail report showing the information available in the National Crime Information Center system. The court found those materials were properly considered because they were part of, or embraced by, the pleadings. The court did not consider the police reports to prove the truth of their narrative descriptions because those reports were materials outside the pleadings.

Federal Civil-Rights Claim

The defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The court applied the same standard used for a motion to dismiss for failure to state a claim: the complaint had to allege enough facts to make the claimed relief plausible. The court treated the video and database report as controlling where they clearly showed what happened.

Excessive force and the investigative stop

The court analyzed the detention as an investigative stop under Terry v. Ohio. It found no dispute that the officers had reasonable suspicion to stop Crow because the vehicle was linked to a person with an active drug warrant who was identified as wanted. The question was whether the manner of the stop was excessively intrusive.

The court concluded that the handcuffs and patrol-car placement were reasonably necessary while the officers verified Crow’s identity. Although Crow was compliant, had no weapon, and told the officers that he was Crow rather than Redkettle, the officers had information indicating that Redkettle was wanted, had a drug warrant, and was considered combative. The court determined that this information gave the officers an objective safety concern and a reasonable basis to use handcuffs and the patrol car briefly. It therefore held that the officers did not use excessive force.

Whether the stop became an arrest

The court also rejected Crow’s argument that the detention became an arrest requiring probable cause. It emphasized that the encounter lasted less than five minutes, Crow was handcuffed for less than three minutes, and the officers promptly investigated the identity discrepancy. The court concluded that the officers diligently pursued a method likely to resolve their suspicion quickly and did not detain Crow longer than necessary.

The court also considered factors including the number of officers and vehicles, the nature of the suspected offense, the safety information in the database, the strength of the officers’ suspicion, Crow’s compliant behavior, and the need for immediate action. On balance, the court found that the investigative stop never became an arrest, so probable cause was not required for the brief detention.

Mistaken identity

The court rejected Crow’s separate mistaken-identity argument. It concluded that the officers had a reasonable, good-faith belief that Crow could be the person sought under the warrant because Crow’s name appeared as an alias for Redkettle and their listed heights and weights were relatively similar. The court also stated that the Fourth Amendment does not require officers to fully investigate a claim of mistaken identity before making a brief detention. Viewing the allegations in Crow’s favor, the court found that the officers’ mistake was, at most, negligent and did not plausibly establish a constitutional violation.

The court therefore dismissed Count One, the § 1983 claim, with prejudice.

Minnesota False-Arrest Claim

The court had supplemental jurisdiction—the authority to hear a related state-law claim in the same case—over Crow’s Minnesota false-arrest claim. After dismissing the federal claim, however, the court declined to continue exercising that jurisdiction under 28 U.S.C. § 1367(c)(3). It dismissed Count Two without prejudice.

Disposition

The court granted the defendants’ motion for judgment on the pleadings. It dismissed the complaint, dismissing the § 1983 claim with prejudice and the false-arrest claim without prejudice. The court entered judgment accordingly.