Stepnes v. Ritschel
663 F.3d 952
| 8th Cir. | 2011Background
- Stepnes organized a mortgage-redemption contest at his foreclosed Minneapolis house, advertised as a skill-based game with a chance-driven weekly prize component.
- Contest required $20 per entry; winner could take the house valued at $1.8 million or $1 million cash, depending on ticket sales.
- The Minnesota Gambling Control Board advised the contest was not gambling if the weekly prize involved skill; later advice acknowledged a chance element.
- Ritschel arrested Stepnes without a warrant after reviewing the contest site and observing a weekly prize drawing; a search warrant was sought and executed the next day.
- Items seized at the Irving Avenue house included the chest of fasteners, a sign, computers, a digital recorder, and photos from the arrest; some fasteners spilled during seizure.
- Stepnes sued Ritschel and Minneapolis under § 1983 for Fourth Amendment violations and Murphy and CBS for defamation; the district court granted summary judgment for the defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the May 28 arrest without a warrant violated the Fourth Amendment | Stepnes | Ritschel/Minneapolis | No Fourth Amendment violation; arguable probable cause supported arrest. |
| Whether handcuffing constituted excessive force | Stepnes | Ritschel | No excessive force; injuries deemed de minimis. |
| Whether the search warrant was exceeded in seizure scope | Stepnes | City | No Fourth Amendment violation; items linked to the alleged illegal lottery and permissible under scope. |
| Whether spoliation sanctions against CBS were appropriate | Stepnes | CBS/Murphy | No abuse of discretion; sanctions denied due to lack of bad faith or gross negligence. |
| Whether Stepnes was a limited-purpose public figure for defamation claims | Stepnes | Murphy/CBS | Stepnes properly deemed a limited-purpose public figure; no actual malice shown. |
Key Cases Cited
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified-immunity framework for officers)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified immunity standard)
- Borgman v. Kedley, 646 F.3d 518 (8th Cir. 2011) (arguable probable cause for warrantless arrest)
- United States v. Rivera, 370 F.3d 730 (8th Cir. 2004) (probable cause standard for arrest)
- Amrine v. Brooks, 522 F.3d 823 (8th Cir. 2008) (no mini-trial before arrest; need for exculpatory evidence)
- Walden v. Carmack, 156 F.3d 861 (8th Cir. 1998) (probable cause supports seizure when linked to crime)
- Taylor v. State of Minn., 466 F.2d 1119 (8th Cir. 1972) (scope of seizure related to crime; permissible items)
- Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974) (limited-purpose public figure standard)
- Chafoulias v. Peterson, 668 N.W.2d 642 (Minn. 2003) (factors for limited public figure designation)
- Jadwin v. Minneapolis Star & Tribune Co., 390 N.W.2d 437 (Minn. 1986) (gist of truth in defamation analysis)
- Murphy v. CBS (relevant context), (not a standalone reporter citation) (—) (defamation framework and malice standards)