Thiel v. Korte, No. 19-1860 (8th Cir. 2020)
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Plaintiff filed suit against the sheriff and sheriff's deputies, alleging that they violated his constitutional right to be free from unreasonable searches and seizures and his right to due process.
The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that the deputies were entitled to qualified immunity because a reasonable officer could believe that the location of the keys to a seized vehicle was reasonably related to the suspected crime because it could provide evidence that plaintiff himself placed the car on the property rather than someone else; the seizure of antique handguns, guns in unopened boxes, and holsters were covered under the second warrant authorizing the seizure of any and all handguns in plaintiff's home; the second warrant was sufficiently particular; the sheriff was entitled to summary judgment on claims against him in his individual capacity and in his official capacity; and plaintiff had an adequate state court remedy to obtain the return of the seized items.
Court Description: [Arnold, Author, with Gruender and Shepherd, Circuit Judges] Civil case - Civil rights. A reasonable officer under the circumstances presented could think the warrant to seize a vehicle included implicit authorization to seize the keys to the vehicle; the second warrant in the case authorized the seizure of any and all handguns in plaintiff's home, and the seizure of antique handguns, guns in unopened boxes and holsters was permitted as they were reasonably related to the suspected crime at issue - discharge of a firearm at a visitor to defendant's home; warrant was sufficiently particular; defendant Korte played no part in obtaining or executing the warrant and plaintiff failed to allege Korte failed to train or supervise his deputies and, as a result, Korte was entitled to summary judgment on the claims against him in his individual capacity; plaintiff failed to allege an actionable custom, and the court did not err in granting Korte summary judgment on plaintiff's official capacity claim; plaintiff had an adequate state court remedy to obtain return of the seized items, and his due-process claim is rejected.
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