Robert Saterdalen v. James Spencer
2013 WL 3970207
8th Cir.2013Background
- Saterdalen, a registered level III predatory offender in Minnesota, failed to report a Belize address as a secondary address under Minn. Stat. § 243.166.
- Rikhus sought a warrant for arrest based on alleged violations related to non-reporting; the statement referenced Belize residence and a Belizean arrest.
- Spencer approved the arrest warrant complaint; a Minnesota judge issued the warrant finding probable cause.
- Saterdalen was arrested in Belize, transported to Texas, then to Minnesota, and detained on a $1 million bail.
- The complaint alleged malicious prosecution and unlawful detention under the Fourth and Fourteenth Amendments; the district court granted judgment on the pleadings for immunity defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rikhus is entitled to qualified immunity | Rikhus lacked probable cause; Belize address should negate exemption. | Warrant application was objectively reasonable given ambiguity and potential primary address issue. | Rikhus granted qualified immunity |
| Whether Spencer is entitled to absolute immunity | Spencer approved warrant despite lack of probable cause. | Reviewing and approving the complaint is a prosecutorial function entitled to absolute immunity. | Spencer granted absolute immunity |
| Whether Belize address constitutes a primary address under Minnesota law | Belize address could be primary due to spending winters there; other reporting suggests compliance. | Belize address not in Minnesota; whether it is primary is ambiguous but objectively reasonable to believe probable cause. | Belize address not a Minnesota primary address; warrant based on reasonable belief |
Key Cases Cited
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity framework for government officials)
- Anderson v. Creighton, 483 U.S. 635 (1987) (objective reasonableness standard for qualified immunity)
- Malley v. Briggs, 475 U.S. 335 (1986) (warrant application must be so lacking as to be unreasonable)
- Kalina v. Fletcher, 522 U.S. 118 (1997) (prosecutor function as advocacy; immunity considerations)
- Buckley v. Fitzsimmons, 509 U.S. 259 (1993) (absolute immunity for prosecutorial functions related to initiating prosecutions)
- Schenk v. Chavis, 461 F.3d 1043 (2006) (preparation, signing, and filing of a criminal complaint as prosecutorial functions)
- Imbler v. Pachtman, 424 U.S. 409 (1976) (basis for prosecutorial absolute immunity)
- Kuehl v. Burtis, 173 F.3d 646 (1999) (minimal further investigation standard for good faith in applying for warrants)
- Williams v. Hartje, 827 F.2d 1203 (1987) (prosecutors absolutely immune for initiating and pursuing prosecutions)
- Messerschmidt v. Millender, 132 S. Ct. 1235 (2012) (probable cause and magistrate issuance considerations in warrants)
- Amrine v. Brooks, 522 F.3d 823 (2008) (objective reasonableness of officer beliefs in probable cause)
- Miller v. United States, N/A (N/A) (placeholder kept for formatting consistency)