Catrina Johnson v. City of Minneapolis
901 F.3d 963
8th Cir.2018Background
- Catrina Johnson called 911 when her 17‑year‑old son became violent; Officers Buck and Heiple responded to the apartment.
- During a hallway takedown of the son (Jareese), Officer Heiple felt a sharp pain in his calf while his back faced Johnson, who had retreated into her apartment wearing a nightgown and soft slippers.
- Heiple asked Johnson twice whether she had kicked him; she denied it both times. Heiple had not seen a kick and did not ask the nearby eyewitness (Mark Moriarty) before arresting Johnson.
- Johnson was arrested for assaulting an officer and spent hours in the ER and three days in jail; charges were later dropped and Heiple now concedes she did not kick him.
- District court denied qualified immunity and state official‑immunity for counts alleging federal unreasonable seizure (§ 1983) and Minnesota false arrest/false imprisonment; the City and Heiple appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Heiple had arguable probable cause to arrest Johnson for assault | Johnson: no probable cause because Heiple had no observation or report that she kicked him and exculpatory facts (position, clothing, stature) made a kick implausible | Heiple/City: arguable probable cause existed based on Heiple’s belief from the scene and Johnson’s emotional state | Held: No arguable probable cause; arrest was objectively unreasonable under the totality of circumstances |
| Whether the Fourth Amendment violation was clearly established | Johnson: existing precedent (e.g., Kuehl) made it clearly established that minimal investigation is required and officers cannot ignore exculpatory evidence | Heiple/City: law not clearly established for these facts | Held: Clearly established; officers could not reasonably believe the arrest was lawful given controlling precedent |
| Qualified immunity for Heiple on § 1983 unlawful seizure claim | Johnson: qualified immunity is not available because no arguable probable cause and violation was clearly established | Heiple/City: entitled to qualified immunity because mistake was objectively reasonable | Held: Qualified immunity denied; appeal affirmed denying it |
| State official immunity (Minnesota) for false arrest/false imprisonment claims against Heiple and vicariously for City | Johnson: official immunity does not apply because Heiple acted with malice by intentionally making an arrest he had reason to believe was prohibited | Heiple/City: claimed official immunity | Held: Official immunity denied for Heiple and vicarious immunity denied for City; factfinder could conclude Heiple had reason to believe he lacked probable cause |
Key Cases Cited
- Kuehl v. Burtis, 173 F.3d 646 (8th Cir. 1999) (officer who spoke briefly with suspect and ignored eyewitness exculpation lacked arguable probable cause)
- District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (probable cause assessed from the whole picture; clearly established‑law guidance)
- McMenomy v. Hoyland, 869 F.3d 644 (8th Cir. 2017) (describing arguable probable cause and qualified immunity standard)
- Brinegar v. United States, 338 U.S. 160 (1949) (probable cause requires more than bare suspicion)
- United States v. Watson, 423 U.S. 411 (1976) (warrantless arrests lawful if supported by probable cause)