Johnson v. City of Minneapolis, No. 17-2074 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of summary judgment based on qualified immunity to a police officer and summary judgment based on official immunity to the City. The court held that the officer lacked arguable probable cause to arrest plaintiff where the totality of the circumstances suggested that the officer had reason to know that plaintiff could not deliver the type of pain he felt (a kick) and he had no information suggesting that she was even in a position to do so. Furthermore, the arguable probable cause undergirding the warrantless arrest here was missing a fundamental element: observation—either by the officer or a witness who relayed that information to him—of a criminal act. The court also held that unlawfulness of the officer's conduct was clearly established at the time. Finally, the court held that a factfinder could determine the officer had reason to believe that he arrested plaintiff without probable cause, and the City, therefore, was not entitled to official immunity.
Court Description: Shepherd, Author, with Melloy and Grasz, Circuit Judges] Civil case - Civil rights. The district court did not err in denying defendant officer's motion for summary judgment based on qualified immunity and the City's motions for summary judgment based on official immunity; it was not objectively reasonable for the officer to arrest plaintiff based on the mistaken belief that plaintiff kicked him as he had reason to know plaintiff could not have delivered the kind of pain he felt and he did not observe plaintiff commit a criminal act and was not told by anyone else that she had; this court has previously held that an officer who did not witness a crime did not have arguable probable cause to arrest a suspect when an officer did minimal investigation, ignored exculpatory evidence and disregarded an eyewitness in close proximity and, as a result, a reasonable officer, looking at the entire legal landscape, could not interpret the law as permitting an arrest; under Minnesota law, a factfinder could determine the officer had reason to believe that he arrested plaintiff without probable cause, and the City, therefore, was not entitled to official immunity.
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