John R. Cutts v. City of Berkeley, Officer O'Shay Conway, and Officer Bryan Sutherland, in their individual and official capacities

CourtDistrict Court, E.D. Missouri
DecidedNovember 10, 2025
Docket4:24-cv-01102
StatusUnknown

This text of John R. Cutts v. City of Berkeley, Officer O'Shay Conway, and Officer Bryan Sutherland, in their individual and official capacities (John R. Cutts v. City of Berkeley, Officer O'Shay Conway, and Officer Bryan Sutherland, in their individual and official capacities) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John R. Cutts v. City of Berkeley, Officer O'Shay Conway, and Officer Bryan Sutherland, in their individual and official capacities, (E.D. Mo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI ) JOHN R. CUTTS, ) ) Plaintiff, ) ) v. ) ) No. 4:24-cv-01102-JMD CITY OF BERKELEY, OFFICER ) O’SHAY CONWAY, and OFFICER ) BRYAN SUTHERLAND, in their ) individual and official capacities, ) ) Defendants. MEMORANDUM AND ORDER Plaintiff John Cutts, a self-represented litigant, sued the City of Berkeley Police Department and Officers O’Shay Conway and Bryan Sutherland. The complaint alleges the City and officers violated the Constitution in how they responded to a 911 domestic disturbance call made by Cutts’ wife. This matter is before the Court on the defendants’ joint motion to dismiss. Cutts is entitled to proceed on just one claim: his claim that Officer Conway unlawfully searched his home. All his other claims fail as a matter of law and are dismissed. Factual Background When reviewing a motion under Rule 12(b)(6), the Court accepts all factual allegations in the complaint as true and draws all reasonable inferences in the nonmovant’s favor. Healy v. Fox, 46 F.4th 739, 743 (8th Cir. 2022). But the Court is not bound by legal conclusions couched as factual allegations. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The following facts alleged in the complaint are therefore accepted as true for purposes of this motion to dismiss, and all doubt is resolved in favor of Cutts. 1 According to Cutts, officers responded to a domestic disturbance call made by Cutts’ wife from his home in Berkeley, Missouri. Officer Sutherland detained Cutts in his front yard for about one hour, while neighbors looked on from their windows. Officer Conway then arrived and searched Cutts’ home without a warrant or consent. Cutts’ wife stated that Cutts had slapped her, but then recanted her allegation and said she was the instigator and had assaulted Cutts. Cutts was not arrested. The City later charged Cutts with two counts of domestic violence. These charges required several court appearances, fingerprinting in a

public court location, and publication of the charges on Missouri’s court documents system, Case.net. The case was dismissed after Officer Conway, a key witness, failed to appear at trial. The circuit court honored Cutts’ request to remove the case from Case.net. Cutts now sues the City and the officers in their official and individual capacities. Cutts’ complaint contains six “legal claims and violations.” ECF 29 at 3. Because complaints filed by laypeople “are to be given liberal construction,” Solomon v. Petray, 795 F.3d 777, 787 (8th Cir. 2015), the Court will “construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework,” id. (internal citation omitted). But even pro se complaints “must allege facts, which if true, state a claim as a matter of law.” Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980) (per curiam). Construing Cutts’ amended complaint liberally, Cutts has filed a claim under § 1983 alleging: (1) a Fourth Amendment violation for a warrantless, nonconsensual search (Officer Conway); (2) a Fourth Amendment violation for unreasonable seizure during the outdoor detention lasting about one hour (both officers); (3) a Fourteenth Amendment due process violation for bringing a prosecution based on false information (all defendants); (4) malicious prosecution for initiating prosecution without probable cause (the City and Officer Conway);

2 (5) due process violations because of stigma he experienced; and (6) municipal liability for these claims under Monell v. Department of Social Services, 436 U.S. 658 (1978), for failure to sufficiently train employees. Defendants move to dismiss all claims. Analysis Section 1983 is not a source of substantive rights. Instead, it is “a vehicle for vindicating federal rights elsewhere conferred by those parts of the United States Constitution and federal statutes that it describes. Accordingly, an underlying constitutional

or statutory violation is a predicate to liability under section 1983.” Henley v. Brown, 686 F.3d 634, 640 (8th Cir. 2012) (internal citations omitted). To survive defendants’ motion to dismiss, Cutts must allege sufficient facts to support an underlying constitutional or statutory violation. With one exception, he fails to do so. I. Counts One and Six: Fourth Amendment Claim Against Officer Conway and Monell Claim Against Conway and the City In Count One, Cutts alleges that Officer Conway unlawfully searched his residence without a “warrant, consent, or lawful justification.” ECF 29 at 3. Cutts claims that after he was already detained in his front yard, Officer Conway arrived and, without obtaining consent, conducted a warrantless search of his home. ECF 29 at 2. In the motion to dismiss, Officer Conway asserts that this allegation does not amount to an underlying Fourth Amendment violation because Officer Conway “accessed the home to question the accuser of Plaintiff (his wife) and investigate the reported crime.” ECF 32 at 4–5. At this stage of litigation, liberally construing the pro se complaint, the Court cannot agree with the motion to dismiss. If what Cutts alleges is true, he has alleged “enough facts to state a claim to relief that is plausible on its face” to survive a motion to dismiss under Rule 12(b)(6), Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). Cutts’ claim is not an 3 example of clarity. Without factual elaboration, he summarily says that the officer searched his house “without probable cause, consent or exigent circumstances.” Arguably, Cutts has pleaded only a legal contention, and only the bare elements. And arguably, Cutts pleaded only that the officer “searched” the home simply by being in the home and observing the home while talking with Cutts’ wife. But it is possible to liberally construe the complaint to allege that the officer searched inside the home beyond what was necessary to question Cutts’ wife. “The Fourth Amendment ordinarily requires that police officers get a warrant before”

a search. Lange v. California, 594 U.S. 295, 298 (2021). “At the very core of the Fourth Amendment stands the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion.” Thompson v. Cockrell, No. 24-2120, 2025 WL 2657074, at *3 (8th Cir. Sept. 17, 2025) (quoting Kyllo v. United States, 533 U.S. 27, 31 (2001) (cleaned up)). While the Fourth Amendment permits many judicially recognized exceptions to the warrant requirement, see Lange, 594 U.S. at 298, the government does not specify any exception that would apply to the facts as alleged here, because Cutts alleges that he was already detained outside the home when police conducted the search. See Caniglia v. Strom, 593 U.S. 194 (2021) (finding a Fourth Amendment violation when the plaintiff had exited the property before the search). According to Cutts’ version of events, the officer did not have a warrant to search the home; Cutts was already detained in the front yard at the time, so there were no exigent circumstances; officers were not given consent for the search; and no arrest was made. ECF 29 at 2. The Eighth Circuit has held that “officers could not enter a residence without a warrant to arrest a domestic violence suspect after the suspect had relocated to a place where the alleged victim was not present.” Cotten v. Miller, 74 F.4th 932, 935 (8th Cir. 2023)

4 (discussing Smith v. Kansas City Police Dep’t, 586 F.3d 576, 580–81 (8th Cir. 2009)).

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Bluebook (online)
John R. Cutts v. City of Berkeley, Officer O'Shay Conway, and Officer Bryan Sutherland, in their individual and official capacities, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-r-cutts-v-city-of-berkeley-officer-oshay-conway-and-officer-bryan-moed-2025.