Parker v. Chard, 0:12-cv-02574

Officers Chard and Illetschko are long‑time Minneapolis police; they began a shift in Uptown Fifth Precinct on Oct. 26, 2011.
An anonymous tip and a Heartbreaker manager report linked “African‑American females” to shoplifting at Victoria’s Secret; officers sought corroboration from Heartbreaker and Victoria’s Secret staff.
Parker and two roommates were in Uptown, parked, shopped, and then Parker was stopped near Victoria’s Secret after leaving Heartbreaker.
Chard blocked Parker’s car, announced an investigation for shoplifting, and obtained consent to search bags; no merchandise was found.
The encounter lasted several minutes; Parker called her father during the stop and remained confined until told she was free to leave; thereafter, Victoria’s Secret video showed the actual suspects committed theft unrelated to Parker.
Parker alleges fear, humiliation, and racial profiling; she pursued §1983 counts and state-law claims; the City sought summary judgment on Monell and related claims.
The Court held the stop itself unlawful, denied qualified immunity for Count I, and dismissed other counts as moot or granted summary judgment to the City on several counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop/seizure was objectively reasonable	Parker argues failure of reasonable suspicion	Officers relied on anonymous tip and corroboration	Unreasonable stop; violation found
Whether the subsequent search with consent was valid	Consent was coerced by unlawful seizure	Consent was voluntary; no coercion shown	Search allowed; qualified immunity applied to search claim
Whether equal protection was violated	Officers targeted African‑Americans	No evidence of discriminatory intent or effect	Equal protection claim dismissed (no showing of discriminatory purpose or effect)
Monell municipal liability against City of Minneapolis	City policy/custom caused the violation	No evidence of policy or custom	Monell claim dismissed with prejudice
Racial discrimination under Minn. Stat. § 363A.12 against City	Disparate impact/motive by officers and city	No causation or discriminatory intent by city	Claim against City dismissed

Florida v. J.L., 541 U.S. 266 (2000) (anonymous tip insufficient without reliability corroboration)
Terry v. Ohio, 392 U.S. 1 (1968) (two-step test for stop and seizure reasonableness)
Wardlow, 528 U.S. 119 (2000) (reliance on location/context in reasonable suspicion)
United States v. Wells, 223 F.3d 835 (8th Cir. 2000) (need for corroboration of anonymous tips)
United States v. Bell, 480 F.3d 860 (8th Cir. 2007) (reliability and credibility of informant examined)
United States v. Wheat, 278 F.3d 722 (8th Cir. 2001) (tip quality and quantity under totality of circumstances)