Blackwell v. City of Richfield Does

CourtDistrict Court, D. Minnesota
DecidedOctober 29, 2024
Docket0:24-cv-02719
StatusUnknown

This text of Blackwell v. City of Richfield Does (Blackwell v. City of Richfield Does) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blackwell v. City of Richfield Does, (mnd 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

RICHARD PRESTON BLACKWELL, Case No. 24-CV-2719 (PJS/TNL) Plaintiff,

v. ORDER CITY OF RICHFIELD DOES; RICHFIELD POLICE DEPARTMENT DOES; COUNTY OF HENNEPIN; UNKNOWN DOES; HENNEPIN COUNTY MEDICAL CENTER; HENNEPIN HEALTHCARE SYSTEM, INC; and UNKNOWN DOES, in their official and individual capacities; Defendants. In July 2018, Richfield police officers transported plaintiff Richard Preston

Blackwell to the Hennepin County Medical Center (“HCMC”) where he was allegedly restrained and administered sedatives and neuroleptic medication without his consent. [ECF No. 1]. This lawsuit followed. Blackwell has not paid the filing fee. Instead, he

asks to proceed in forma pauperis (“IFP”). [ECF No. 2]. Blackwell’s complaint and IFP application are therefore before the Court for preservice review pursuant to 28 U.S.C. § 1915(e)(2). Based on that review, the Court dismisses all of Blackwell’s claims—the federal claims with prejudice and the state-law claims without. Blackwell’s IFP application, [ECF No. 2], is denied as moot.

I. BACKGROUND

Blackwell alleges the following: On July 21, 2018, Blackwell was sitting in his car with a towel on his head when

unnamed Richfield police officers approached him. Even though Blackwell told the officers that he had recently been sexually assaulted, the officers did not write a report or investigate his sexual assault. Instead, they continued to ask him questions about why he was sitting in a parked car with a towel on his head. Eventually, the officers

left. Later the next day (July 22, 2018), Blackwell called 911 to report theft, property

damage, and stalking. He told the 911 operator that he would be waiting for the police at the intersection of Clinton Avenue and 67th Street—the same location where he had encountered the police the day before. When unnamed Richfield police officers arrived,

Blackwell told them that the same people who had sexually assaulted him had broken into his car and were stalking him. Rather than investigate his reports, an unnamed Richfield police officer asked Blackwell if she could place him in handcuffs and put him in her squad car. During this time, additional unidentified Richfield police officers

arrived, and they began to search Blackwell’s vehicle without his permission. Eventually, Blackwell was transported to HCMC, where unnamed medical professionals restrained him and administered sedatives and neuroleptic medications

over his objection. When Blackwell awoke, he was discharged from the hospital even though he was still under the influence of the medications. Blackwell lost consciousness while riding on the light rail, and later, when he tried to sleep, he slept

for 24 hours. Blackwell asserts federal causes of action under 42 U.S.C. §§ 1981, 1983, and 1988,

as well as violations of Minnesota state law. II. STANDARD OF REVIEW

Pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii), an IFP application will be denied, and an action will be dismissed, when an IFP applicant has filed a complaint that fails to state a claim on which relief may be granted. See Atkinson v. Bohn, 91 F.3d 1127, 1128 (8th Cir.

1996) (per curiam). In reviewing whether a complaint states a claim for which relief may be granted, this Court must accept the complaint’s factual allegations as true and draw all reasonable inferences in the plaintiff’s favor. Varga v. U.S. Nat’l Bank Ass’n, 764

F.3d 833, 838 (8th Cir. 2014). The factual allegations need not be detailed, but they must be sufficient “to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). The complaint must “state a claim to relief that is plausible on its face.” Id. at 570. Pro se complaints are to be construed liberally, but they must nevertheless allege enough facts to support the claims advanced. Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004).

III. ANALYSIS Blackwell asserts causes of action under both federal and state law. The Court

will address each claim in turn, beginning with the federal claims. A. 42 U.S.C. § 1983 “To state a claim under 42 U.S.C. § 1983, a plaintiff must allege a violation of a

constitutional right committed by a person acting under color of state law.” Andrews v. City of West Branch, 454 F.3d 914, 918 (8th Cir. 2006). “Public servants may be sued under section 1983 in either their official capacity, their individual capacity, or both.” Johnson v. Outboard Marine Corp., 172 F.3d 531, 535 (8th Cir. 1999). Individual-capacity

and official-capacity claims differ in their pleading requirements, in the defenses available to the defendants, and in the potential relief available to the plaintiffs. See Hafer v. Melo, 502 U.S. 21, 25-27 (1991). Here, each defendant is named in that person’s

individual capacity and in that person’s official capacity as an agent of the entity for which he or she worked (either the City of Richfield or Hennepin County).

Turning first to Blackwell’s individual-capacity claims: “Suits against officials in their individual capacity seek to impose personal liability upon a government official for actions he takes under color of state law.” Handt v. Lynch, 681 F.3d 939, 943 (8th Cir. 2012) (quoting Kentucky v. Graham, 473 U.S. 159, 165 (1985)). To establish liability against officials in their individual capacity, “the plaintiff must show that the official, acting under color of state law, caused a deprivation of a federal right.” Id. Put another

way, it is not enough for a plaintiff seeking relief from a defendant in the defendant’s individual capacity to allege that his rights were violated by someone; the plaintiff must instead allege that his rights were violated by the particular defendant.

Blackwell does not identify a single individual defendant by name. Instead, he refers to the individual defendants as “City of Richfield Does,” “Richfield Police

Department Does,” and “Unknown Does.” [ECF No. 1]. Presumably, Blackwell anticipates that he will discover the names of these individuals later in the litigation. The problem with this approach, however, is that the statute of limitations for asserting a § 1983 action in Minnesota is six years, see Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615,

618 n.3 (8th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Zutz v. Nelson
601 F.3d 842 (Eighth Circuit, 2010)
Moor v. County of Alameda
411 U.S. 693 (Supreme Court, 1973)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Hafer v. Melo
502 U.S. 21 (Supreme Court, 1991)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Donald Earl Atkinson v. Susan Bohn Phil Jefferson
91 F.3d 1127 (Eighth Circuit, 1996)
Johnson v. Outboard Marine Corp.
172 F.3d 531 (Eighth Circuit, 1999)
Carl Youngblood v. Hy-Vee Food Stores, Inc.
266 F.3d 851 (Eighth Circuit, 2001)
Michael Handt v. Steve Koffron
681 F.3d 939 (Eighth Circuit, 2012)
Baker v. Chisom
501 F.3d 920 (Eighth Circuit, 2007)
Geoffrey Varga v. U.S. Bank National Association
764 F.3d 833 (Eighth Circuit, 2014)
Jennifer Heglund v. City of Grand Rapids
871 F.3d 572 (Eighth Circuit, 2017)
Andrews v. City of West Branch
454 F.3d 914 (Eighth Circuit, 2006)

Cite This Page — Counsel Stack

Bluebook (online)
Blackwell v. City of Richfield Does, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blackwell-v-city-of-richfield-does-mnd-2024.