Waters v. Madson

The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss the amended complaint in an action brought by plaintiff and his wife after plaintiff refused to allow Menards home supply store employees, pursuant to posted store policy, to search the trunk of his vehicle as he exited a Menards lumberyard in Coon Rapids, Minnesota. The court held that the officers were entitled to qualified immunity on the Fourth Amendment seizure claims because they had arguable reasonable suspicion in detaining plaintiff when he refused to open his vehicle's trunk; there was no unreasonable delay or unreasonable force in the detention and the officers did not arrest plaintiff; and it was reasonable for the officers to briefly handcuff plaintiff in light of his unpredictability, evasiveness, argumentative demeanor, refusal to disobey legitimate officer commands, and the size difference between plaintiff and the officers.The court also held that the officers were entitled to qualified immunity on the wife's Fourth Amendment seizure claim where the wife was a passenger in the car and the officers had reasonable suspicion for detaining her; a de minimis use of force could not, as here, form the basis for a Fourth Amendment excessive force claim; plaintiff failed to adequately plead a compensatory damages claim under 42 U.S.C. 1983 arising from the officers' search of the vehicle's trunk; and plaintiff's remaining First Amendment and state law claims were rejected. View "Waters v. Madson" on Justia Law