Court: District Court, D. Minnesota; July 18, 2014; Federal District Court
On May 13, 2014, oral arguments were heard regarding Defendant Richard W. Stanek’s Motion for Summary Judgment and Plaintiff Rebecca J. Wall’s Motion for Partial Summary Judgment. The court granted Stanek’s motion and denied Wall’s. The background involves an incident on June 20, 2011, when Hennepin County Sheriff's Deputy Barbara Russeth stopped Wall for suspected impaired driving. Following field sobriety tests and a Preliminary Breath Test showing a blood alcohol concentration (BAC) of .109, Wall was arrested for DWI. Under Minnesota law, individuals driving in the state give implied consent for chemical testing if there is probable cause of impaired driving. After Wall was taken to the patrol headquarters, Russeth read her the Minnesota Implied Consent Advisory, highlighting the legal requirement to submit to testing and the criminal implications of refusal. Wall subsequently consented to a urine sample; however, she claimed Russeth’s presence compromised her ability to do so privately. Russeth then transported Wall to Hennepin County Medical Center for a blood draw, which revealed a BAC of .06 over two hours post-stop, below the legal limit. All charges against Wall were eventually dropped. Wall has since filed a lawsuit under 42 U.S.C. § 1983, arguing that the use of the Implied Consent Advisory constituted an unconstitutional search and seizure under the Fourth Amendment, alleging that her consent was coerced by Hennepin County’s policy. Stanek, in his official capacity, is accused of enforcing a policy that allegedly undermines individuals' rights by compelling consent under the implied consent law. Hennepin County asserts that its officers acted within the law and that Wall’s consent was voluntarily given.
Summary of Key Points:
1. **Standard of Review**: Under Federal Rule of Civil Procedure 56(a), summary judgment is appropriate when there is no genuine issue of material fact, and the moving party is entitled to judgment as a matter of law. The court must view evidence in the light most favorable to the nonmoving party, who cannot rely solely on allegations but must present specific facts creating a genuine trial issue.
2. **42 U.S.C. § 1983**: This statute holds individuals liable for actions taken under state law that violate constitutional rights. A lawsuit against a public official in their official capacity effectively targets the entity they represent. Municipal liability under § 1983 arises when a policy or custom of the municipality causes the alleged constitutional violation, with the requirement that this policy or custom is the "moving force" behind the violation. Inadequate police training can be a basis for liability if it reflects deliberate indifference to citizens' rights.
3. **Deliberate Indifference**: Establishing deliberate indifference requires showing that the municipality was aware its training procedures were inadequate and likely to result in constitutional violations. This can be demonstrated by proving that the need for training was obvious or that a pattern of constitutional violations indicated insufficient responses to recurring situations.
4. **Warrant and Implied Consent Advisory**: Before 2013, Minnesota case law allowed for warrantless blood draws based on the rapid dissipation of alcohol and affirmed the constitutionality of Minnesota’s Implied Consent and Refusal Law. However, developments in 2013 raised questions about these legal principles.
In 2010, Tyler McNeely was arrested for DWI in Missouri and refused a blood sample after being informed of the state's implied consent law. The arresting officer then performed a warrantless forcible blood draw, which McNeely sought to suppress. The Missouri Supreme Court ruled in January 2012 that this action was unreasonable and violated the Fourth Amendment (Missouri v. McNeely, 358 S.W.3d 65). Missouri petitioned the U.S. Supreme Court, which granted certiorari on September 25, 2012. In April 2013, the U.S. Supreme Court affirmed that the unconsented forcible blood draw violated the Fourth Amendment, emphasizing that while the rapid dissipation of alcohol is a factor, exigent circumstances must be evaluated case-by-case (Missouri v. McNeely, 569 U.S. 141).
Following this decision, the U.S. Supreme Court remanded Wesley Brooks' case to the Minnesota Supreme Court for reconsideration. Brooks' case involved three incidents in 2009 and 2010 where he was read the Implied Consent Advisory and consulted a lawyer before providing samples. He argued that the warrantless searches of his blood and urine could not be justified solely on the basis of alcohol dissipation. The Minnesota Supreme Court concurred, stating that while exigent circumstances could allow warrantless blood draws, they must assess these circumstances on a case-by-case basis (State v. Brooks, 838 N.W.2d 563).
Brooks contended that he did not truly consent to the testing because he believed refusing the test was a crime. The Minnesota Supreme Court ruled that the mere existence of a penalty for refusal does not equate to coercion. They found no other indications of coercion and held that Brooks voluntarily consented to the searches. The U.S. Supreme Court later denied Brooks' petition for a writ of certiorari (Brooks v. Minnesota, 569 U.S. 141).
In light of the Brooks decision, it was concluded that Wall could not establish valid Monell claims against Hennepin County, as the implied consent advisory merely reflects Minnesota's implied consent law and does not demonstrate a violation of constitutional rights under the Fourth Amendment.
Wall's argument hinges on the assertion that the reading of the Implied Consent Advisory constituted coercion, which lacks additional factual support beyond Russeth's reading. The Minnesota Supreme Court has upheld the constitutionality of the implied consent law, indicating that Wall's coercion claim is untenable. Furthermore, even if the law had been deemed unconstitutional, Wall's claim would still fail as her arrest occurred in 2011, prior to the establishment of the law’s constitutionality. Wall cannot demonstrate that Hennepin County displayed deliberate indifference regarding its procedures, as she cannot show that the county was aware of any inadequacies leading to constitutional rights violations. The court ordered the granting of the defendant’s motion for summary judgment, the denial of Wall’s motion for partial summary judgment, and the dismissal of all claims in the complaint with prejudice. Wall's argument that the arresting officer did not inform her of her blood alcohol concentration exceeding the legal limit is noted, but she does not contest the probable cause for her arrest. Wall's reference to the Supreme Court case Bumper v. North Carolina is rejected, as the Minnesota Legislature allows drivers to refuse chemical tests, distinguishing it from the precedent cited.
