Woodard v. City of Bloomington Police Department

Background

Jyron Mendale Woodard filed a civil-rights complaint under 42 U.S.C. § 1983 concerning his February 16, 2022 arrest. The complaint alleged that Officer Chris Wegner and Officer Amanda Johnson, along with unknown officers, used excessive force in violation of the Fourth and Fourteenth Amendments. Woodard also asserted state-law claims for assault and battery and intentional infliction of emotional distress. He further alleged that the cities of Bloomington and Richfield failed to train officers to avoid misidentifying plainclothes officers.

The court had previously dismissed the City of Bloomington Police Department and City of Richfield Police Department from the case without prejudice to suing the relevant cities themselves. Woodard did not sue those entities. His remaining named defendants were Wegner, Johnson, and Unknown Officers #1-30. Woodard litigated the case without a lawyer.

Summary-Judgment Analysis

The court applied the Fourth Amendment’s objective-reasonableness test for excessive-force claims. That test requires evaluating the total circumstances from the viewpoint of a reasonable officer at the scene, including the seriousness of the suspected crime, the danger posed by the person being arrested, and whether the person was fleeing or resisting.

Woodard’s complaint said that the officers approached his vehicle with a firearm without identifying themselves, causing him to run for safety. He alleged that the officers chased him, tackled him, struck his head against uneven ice, restrained his hands, and applied substantial pressure to his back for more than 30 seconds. He said he was taken to a hospital and spent several days there.

The court found that Woodard offered no evidence beyond the allegations in his complaint to support his account. The officers submitted body-camera footage and police reports. According to that evidence, Johnson was investigating a stolen-vehicle suspect when a vehicle driven by Woodard arrived. Johnson said her badge was visible and her handgun remained holstered. After she asked Woodard for the vehicle’s registration, he drove away, went onto sidewalks and through yards, and crashed into a fence. Woodard then ran from the vehicle.

The footage showed Wegner and Johnson chasing Woodard and repeatedly ordering him to stop. Wegner caught him, and both men fell. Afterward, Wegner repeatedly ordered Woodard to put his hands behind his back while Woodard tried to roll onto his side. The officers had lost their handcuffs during the chase, so they held Woodard on the ground and used body weight on his legs and back until another officer arrived and handcuffed him. They stopped applying pressure after he was handcuffed. Officers took Woodard to a hospital because his head was bleeding and he reported swallowing heroin; footage showed that he was discharged later that evening.

Considering the total circumstances, the court concluded that the three factors identified in Graham v. Connor supported the officers’ actions and that their conduct did not violate the Fourth Amendment. It therefore recommended granting summary judgment to Wegner and Johnson on Woodard’s individual-capacity excessive-force claim.

Qualified Immunity

The officers also argued that qualified immunity protected them. Qualified immunity generally protects government officials from damages when the evidence does not show a violation of a constitutional right or the right was not clearly established. Because the court found no constitutional violation, it did not conduct the second part of the qualified-immunity analysis.

Official-Capacity and Failure-to-Train Claims

The court treated Woodard’s official-capacity claims against Wegner and Johnson as claims against the cities for which they worked, Bloomington and Richfield. Under § 1983, a city is not automatically responsible for an employee’s conduct. A city may be liable under Monell v. Department of Social Services only when an unconstitutional policy, custom, or deliberately indifferent failure to train or supervise was the moving force behind a constitutional violation.

Because the court found no underlying constitutional violation by Wegner or Johnson, it concluded that neither city could be held liable under Monell. It therefore recommended dismissing Woodard’s official-capacity claims with prejudice.

State-Law Claims

The federal court had supplemental jurisdiction over Woodard’s related state-law claims because they arose from the same incident as his federal claims. After recommending dismissal of all federal claims, however, the court recommended declining to continue exercising supplemental jurisdiction over the assault, battery, and intentional-infliction-of-emotional-distress claims. It recommended dismissing those state-law claims without prejudice.

Request for a Medical Expert

Woodard asked the court to appoint a medical expert to determine the force and pressure needed to cause his head injury. The court treated this as a request under Federal Rule of Evidence 706. It denied the request without prejudice because Woodard had not shown compelling circumstances, the decision on summary judgment rested on the reasonableness of the officers’ actions rather than a lack of medical evidence, and the excessive-force issue was not too complex for the court to understand without an appointed expert.

Unknown Officers

Woodard had not identified or served Unknown Officers #1-30, even though the case had been pending for nearly two years and he had had an opportunity to identify them through discovery and amend his complaint. The court ordered Woodard to file, within 21 days, an affidavit, memorandum, or other documentation explaining why those defendants should not be dismissed for failure to serve them. If he did not respond, the court stated that it would recommend dismissing the unknown officers without prejudice.

Disposition and Review

The recommendation was to grant Wegner and Johnson’s motion for summary judgment and dismiss claims against them in their individual and official capacities with prejudice. The separate order denied the request for appointment of a medical expert without prejudice and required Woodard to show cause regarding Unknown Officers #1-30. The document was a magistrate judge’s Report and Recommendation and Order, not a final district-court judgment. The notice stated that it was not directly appealable to the Eighth Circuit and that objections could be filed under the applicable local rule.