Brown v. City of Minneapolis, The et al

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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
WILLIE B. BROWN, JR.,
Plaintiff,
v.
THE CITY OF MINNEAPOLIS;
MICHAEL A. HEYER, Minneapolis
Police SGT; PATRICK BRYAN,
Minneapolis Police Officer; SHANY,
Partner Officer of the 4th Precinct,
Individually and in their official
capacities; HENNEPIN COUNTY; JOHN
DOE, HCMC SECURITY GUARDS, 4-
5; JANE DOE, HCMC Security Guards,
1-2; SHALA JACOBSON, Nurse; JANE
DOE, Nurse 1; SUPERVISORS,
Individually and in their official
capacities; and THE HENNEPIN
COUNTY MEDICAL CENTER,
Defendant.
Case No. 26-CV-0713 (PAM/JFD)
REPORT AND RECOMMENDATION
In 2018, the State of Minnesota charged plaintiff Willie B. Brown, Jr., with charges
of second-degree murder, drive-by shooting, and second-degree assault. See State of
Minnesota v. Brown, No. A19-0409, 2020 WL 4932785, at *1 (Minn. Ct. App. Aug. 24,
2020). A jury found Mr. Brown guilty of all three offenses, but the Minnesota Court of
Appeals remanded for a new trial on multiple grounds. One of the grounds on which
remand was ordered is relevant to this lawsuit. Following Mr. Brown’s arrest in April 2018,
law-enforcement officials procured a search warrant to forcibly obtain a blood sample from
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Mr. Brown. The trial court denied a motion from Mr. Brown to suppress evidence related
to the blood draw, but the Minnesota Court of Appeals concluded that the search warrant
did not contain sufficient facts to establish probable cause for conducting the search. See
id. at 12-13.
Mr. Brown had won the battle but lost the war. On remand, Mr. Brown was found
guilty on all three charges, notwithstanding the exclusion of the evidence resulting from
the blood test. This time, the convictions were affirmed on appeal. See State of Minnesota
v. Brown, No. A22-0621, 2023 WL 3806696, at *7 (Minn. Ct. App. June 5, 2023). Mr.
Brown is currently serving the lengthy sentence imposed as a result of those convictions.
In this action, Mr. Brown seeks monetary relief pursuant to 42 U.S.C. § 1983 from
multiple law-enforcement officials and medical professionals for having carried out the
blood draw later found by the Minnesota Court of Appeals to be unlawful. Because Mr.
Brown is a prisoner, his complaint is subject to preservice review. See 28 U.S.C. § 1915A
(“The court shall review, before docketing, if feasible or, in any event, as soon as
practicable after docketing, a complaint in a civil action in which a prisoner seeks redress
from a governmental entity or officer or employee of a governmental entity.”). As a result
of that review, this Court concludes that this action is plainly untimely and should be
summarily dismissed on that basis.
“The statute of limitations for a § 1983 claim is generally the applicable state-law
period for personal-injury torts.” City of Rancho Palos Verdes, California v. Abrams, 544
U.S. 113, 123 n.5 (2005). In Minnesota, the six-year limitations period established by
Minn. Stat. § 541.05 applies to claims brought under § 1983. See Rassier v. Sanner, 996
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F.3d 832, 836 (8th Cir. 2021). The search at issue took place in April 2018. See Amended
Complaint ¶¶ 14-30 [Dkt. No. 4]. Six years onward from April 2018 is April 2024. Mr.
Brown did not commence this action until January 2026. Obviously, more than six years
elapsed between the date of the blood draw and the date Mr. Brown commenced suit.
Section 541.05 therefore would seem to squarely foreclose Mr. Brown’s claims from going
forward.
Mr. Brown, however, points to Minn. Stat. § 541.15(a), which provides (in relevant
part) the following:
[A]ny of the following grounds of disability, existing at the
time when a cause of action accrued or arising anytime during
the period of limitation, shall suspend the running of the period
of limitation until the same is removed; provided that such
period, except in the case of infancy, shall not be extended for
more than five years, nor in any case for more than one year
after the disability ceases:
(1) that the plaintiff is within the age of 18 years;
(2) the plaintiff's insanity;
(3) is an alien and the subject or citizen of a
country at war with the United States;
(4) when the beginning of the action is stayed by
injunction or by statutory prohibition.
If two or more disabilities shall coexist, the suspension shall
continue until all are removed.
The amended complaint alleges that “[a]t the time of the assault plaintiff had already been
diagnosed with several mental health conditions including, mild schizophrenia personality
disorder and severe depression which only got worst after the assault accrued which would
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explain plaintiff[’]s delay regarding this matter.” Amended Complaint at 8. Mr. Brown
contends that § 541.15(a)(2) therefore results in his claims being timely as a matter of state
law.
There are two problems with this argument. The first problem is that a showing of
insanity requires more than that the plaintiff suffers from mental health conditions. Rather,
“under the statute insanity means substantial inability, by reason of mental defect or
deficiency, to understand one’s legal rights, manage one’s affairs, and prosecute the claim.”
Harrington v. County of Ramsey, 279 N.W. 2d 791, 795 (Minn. 1979). There is no reason
to believe that Mr. Brown has ever suffered from such a substantial inability—at a
minimum, he has not alleged facts establishing as much. The second problem is that, even
if Mr. Brown did labor under such a substantial inability at the time of the events at issue,
he cannot plausibly contend to have been unable to prosecute his claims for relief any later
than March 2021, when Mr. Brown filed a lawsuit against the State of Minnesota and
Minneapolis Police Department raising claims similar to those brought in this action. See
Brown v. State of Minnesota, No. 27-CV-21-2453 (Minn. Dist. Ct.). Under the plain
language of the statute, § 541.15(a) could not be invoked to extend the limitations period
for more than a year beyond that date (which would have been unnecessary, as the six-year
limitations period would not expire until April 2024). Even if an additional year were
added to the limitations period (contrary to the language of § 541.15(a)), Mr. Brown would
have been required to seek relief by no later than April 2025. This action was not
commenced until January 2026.
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One other argument, not raised by Mr. Brown, is worth considering if only to reject
it. A litigant cannot bring claims for monetary relief under § 1983 that would necessarily
call into question the legality of a conviction that has not otherwise been invalidated. See
Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). Any suggestion by Mr. Brown that the
Heck doctrine precluded him from seeking relief during the limitations period, therefore
necessitating that the statute of limitations be tolled, must be rejected for the simple reason
that Heck was never an impediment to Mr. Brown seeking relief.1 As later events bore out,
any claims regarding the insufficiency of the search warrant or illegality of the blood draw
would not necessarily imply the invalidity of Mr. Brown’s conviction, as the State of
Minnesota was able to procure convictions despite the evidence resulting from the search
having been excluded from trial. At no point would Heck have had any effect on Mr.
Brown’s ability to litigate his claims. Equally, then, Heck has no bearing on the effect of
the statute of limitations governing those claims.
Mr. Brown waited too long to seek relief under § 1983. This action should therefore
be dismissed with prejudice pursuant to § 1915A. See Varner v. Peterson Farms, 371
F.3d 1011, 1016, 1019-20 (8th Cir. 2004) (affirming dismissal with prejudice of claims
barred by statute of limitations).
1 Relatedly, so too must any argument that Mr. Brown’s claim did not accrue until the
Minnesota Court of Appeals concluded that the search warrant that led to the blood draw
at issue was not supported by probable cause. Mr. Brown’s cause of action accrued when
the search occurred, not when the process leading to the search was found to be unlawful.
See Wallace v. Kato, 549 U.S. 384, 390-91 (2007).
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RECOMMENDATION
1. 	Based on the foregoing, and on all of the files, records, and proceedings
herein, IT IS HEREBY RECOMMENDED that this matter be DISMISSED WITH
PREJUDICE pursuant to 28 U.S.C. § 1915A(b).
Date: February 23, 2025 	s/ John F. Docherty
JOHN F. DOCHERTY
United States Magistrate Judge
NOTICE
Filing Objections: This Report and Recommendation is not an order or judgment of the
District Court and is therefore not appealable directly to the Eighth Circuit Court of
Appeals. Under Local Rule 72.2(b)(1), “a party may file and serve specific written
objections to a magistrate judge’s proposed finding and recommendations within 14 days
after being served a copy” of the Report and Recommendation.
A party may respond to those objections within 14 days after being served a copy of the
objections. See Local Rule 72.2(b)(2). All objections and responses must comply with the
word or line limits set forth in Local Rule 72.2(c).
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