Wendt v. Iowa, No. 19-3300 (8th Cir. 2020)
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After plaintiffs received criminal citations for trespassing and traffic violations while hunting, they filed suit alleging unreasonable search and seizure under the Fourth Amendment and Iowa Constitution, as well as violations of their substantive due process rights.
The Eighth Circuit affirmed the district court's dismissal of the unreasonable seizure claim for failure to state a claim where the district court found no seizure under the prevailing federal standards because the officers were alleged only to have issued or verified citations. The court also affirmed the district court's grant of summary judgment to the officers on the unreasonable search claims where the district court did not err in considering summary judgment for the unreasonable search claims under the Iowa Constitution; the district court properly refused to consider plaintiffs' claim that the warrants for their Facebook records were overbroad; and the district court properly ruled that plaintiffs' allegation that defendants placed a GPS tracker on one of the plaintiff's vehicles is, at best, speculative and contradicts all objective evidence on the record. Finally, the court affirmed the district court's grant of summary judgment on the substantive due process claims where plaintiffs point to no evidence in the record that the officers intentionally or recklessly failed to investigate in a way that shocks the conscience.
Court Description: [Benton, Author, with Colloton and Wollman, Circuit Judges] Civil case - Civil rights. The service or verification of a citation is not a seizure for Fourth Amendment purposes and the count of plaintiff's complaint alleging the issuance and verification violated their Fourth Amendment rights was properly dismissed for failure to state a claim; the district court did not err in considering summary judgment for plaintiff's unreasonable search claims under the Iowa Constitution; the district court did not err in granting defendants summary judgment on plaintiffs' claim the warrants for their Facebook records were overbroad; further, the district court did not err in finding defendants were entitled to qualified immunity on plaintiffs' claim that the warrant applications were not supported by probable cause; the district court did not err in granting defendants summary judgment on plaintiff's allegations concerning the placement of a GPS tracker as the record did not support the claim that a tracking device had been placed on plaintiff Wendt's truck; there was no evidence the officers intentionally or recklessly failed to investigate the case such that their conduct would shock the conscience and violate plaintiffs' due process rights. [ August 20, 2020 ]
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