Stepnes v. Ritschel, et al., No. 11-1381 (8th Cir. 2011)
Annotate this CaseA police sergeant arrested plaintiff without a warrant for running a contest which allegedly violated Minnesota gambling laws. The sergeant later obtained a search warrant and seized several items from the house where plaintiff was running the contest. A reporter broadcasted a news story about the contest and plaintiff's arrest on a local CBS television station. Plaintiff subsequently sued the sergeant and the city of Minneapolis under 42 U.S.C. 1983 for civil rights violations for the arrest and search, and the reporter and CBS for defamation. Both sides moved for summary judgment and the district court granted the motion for defendants. The court held that because plaintiff failed to demonstrate that any of the sergeant's actions violated a constitutional right, he could not deprive the sergeant of qualified immunity, and thus summary judgment was appropriate. Summary judgment was also proper as to the city because municipalities could not be held liable under Section 1983 where plaintiff had not argued on appeal that any municipal policy or custom led to a deprivation of his constitutional rights. The court also held that plaintiff was a limited purpose public figure and it was not reckless disregard for the truth to conclude that plaintiff could face future incarceration related to the contests. The court further held that the district court did not abuse its substantial discretion in denying plaintiff's motion for spoliation sanctions. Accordingly, the judgment of the district court was affirmed.
Court Description: Civil case - civil rights. Officer had probable cause to arrest plaintiff based on his belief that plaintiff was running an illegal lottery; plaintiff did not state a claim for excessive force as he produced no evidence that he suffered anything beyond minor injuries during handcuffing; search of plaintiff's home did not exceed the scope of the warrant; with respect to plaintiff's defamation claims against CBS and a media defendant, the district court correctly determined that plaintiff was a limited purpose public figure, and the court did not err in finding that the allegedly defamatory statements were not made with reckless disregard of the truth; district court did not abuse its substantial discretion in denying plaintiff's spoilation of evidence claim against CBS.
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