Mountain Pure v. Roberts, No. 15-1656 (8th Cir. 2016)
Annotate this CaseThis case stemmed from a government investigation of Mountain Pure's bottling facility. Mountain Pure and its employees filed suit against defendants, government agents, under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging violations of their Fourth Amendment rights. The district court granted summary judgment for defendants. The court concluded that the district court did not err in granting Defendants Roberts and Spradlin summary judgment on Mountain Pure's excessive force claim, nor did the district court err in granting the agents summary judgment on Mountain Pure's claim alleging unlawful seizure of its property. In regard to the individual employees' arguments that the district court erred in granting summary judgment against them on their claims alleging unlawful detention, unlawful seizure of their property, and excessive force, the court concluded that: the detention of the employees during the execution of the search warrant was reasonable where detaining the employees prevented them from fleeing in the event that incriminating evidence was found and ensured that they would be present to assist with the completion of the search such as by opening locked file cabinets to avoid the use of force, and detention of the employees in the break room was not particularly intrusive; the length of the detentions here was reasonable given that the search took nearly twelve hours and the government had a legitimate interest in detaining the employees during the search; the employees' argument that qualified immunity should not apply in Roberts' and Spradlin's case is rejected where there is no evidence showing that the interrogations at issue prolonged the employees' detentions beyond a reasonable time; Roberts and Spradlin did not act unreasonably in detaining them incommunicado by denying them access to telephones; the district court did not err in concluding that qualified immunity barred the employees' claims alleging an unlawful seizure of their property; and the district court did not err in granting summary judgment for Roberts and Spradlin on Bush, Morgan, and Stacks' excessive force claims. Accordingly, the court affirmed the judgment.
Court Description: Murphy, Author, with Smith and Benton, Circuit Judges] Civil case - Bivens action. The number of agents used in a raid was reasonable and their possession of weapons was required by agency policies governing the execution of search warrants and was. therefore, legally reasonable; nor did the court err in granting the defendant agents summary judgment on plaintiff's claim that the agents unlawfully seized certain property as a reasonable agent could believe the disputed items were covered by the warrant; detention of employees in a break room while the agents conducted the search was justified by governmental interests and was not particularly intrusive; the length of detention was reasonable given the time it took to complete the search of plaintiff's facility; there was no evidence showing that the interrogations at issue prolonged the employees' detention beyond a reasonable time; the agents' actions in denying the employees access to phones or seizing the phones was entitled to qualified immunity as the court is unaware of any cases invalidating a seizure of detainees' cell phones during the execution of a warrant; while there is evidence that unidentified federal agents pushed two of the employees and pointed a gun at a third, there was no evidence the two named defendants participated in, ordered or condoned the alleged use of excessive force, and they were entitled to summary judgment on the claims. [ February 24, 2016
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