Haynes v. Minnehan, No. 20-1777 (8th Cir. 2021)
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On a well-lit summer evening in a Des Moines neighborhood with community-reported drug crimes, police officers Minnehan and Steinkamp lawfully stopped Haynes for suspected (mistaken) involvement in a drug deal. The exceedingly polite and cooperative exchange between the three did not make either officer view Haynes as a safety risk. Haynes could not find his driver’s license but shared three separate cards bearing his name. Steinkamp then handcuffed him. While the polite interaction continued, the cuffs stayed on. They also stayed on after a clean frisk and a consensual pocket search. They stayed on after the officers declined Haynes’s invitation to search another pocket and Haynes’s car. The officers declined another squad car’s offer to help.
The district court rejected, on summary judgment, Haynes’s Fourth Amendment claims. 42 U.S.C. 1983. The Eighth Circuit reversed. Handcuffs constitute “greater than a de minimus intrusion,” their use requires the officer to demonstrate that the facts available to the officer would warrant a man of reasonable caution in believing that the action taken was appropriate. Here, the officers failed to point to specific facts supporting an objective safety concern during the encounter. Minnehan and Steinkamp had fair notice that they could not handcuff Haynes without an objective safety concern.
Court Description: [Grasz, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge] Civil case - Civil rights. In this action alleging defendants violated plaintiff's Fourth Amendment rights by leaving him handcuffed after a clean frisk and in a longer-than-necessary traffic stop, the district court erred in granting the officers' motion for summary judgment based on qualified immunity; given the circumstances presented, the officers failed to point to specific facts supporting an objective safety concern during the encounter, and the the way the officers conducted the seizure was not reasonably related in scope to the circumstances which justified the interference in the first place; existing case law would have fairly notified every reasonable officer in the defendants' position that their conduct violated the Constitution. Judge Shepherd, dissenting. [ September 20, 2021 ]
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