Parada v. Anoka County

U.S. District Court, District of Minnesota

Parada v. Anoka County

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Myriam Parada,                      Case No. 18-cv-795 (JRT/TNL)         

          Plaintiff,                                                     

v.                                           ORDER                       

Anoka County; Anoka County Sheriff                                       
James Stuart; Coon Rapids Police Officer                                 
Nicolas Oman; City of Coon Rapids; and                                   
Unknown/Unnamed Defendants John Doe                                      
& Jane Doe; All individuals being sued in                                
their individual and official capacity,                                  

          Defendants.                                                    


Alain M. Baudry, Saul Ewing Arnstein & Lehr LLP, 33 South Sixth Street, Suite 4750, 
Minneapolis, MN 55402; Amanda R. Cefalu and Nathan T. Boone, Kutak Rock LLP, 
60 South Sixth Street, Suite 3400, Minneapolis, MN 55402; Ian Bratlie, ACLU of 
Minnesota, 709 South Front Street, Suite 1B, Mankato, MN 56001; and Teresa J. 
Nelson, ACLU of Minnesota, P.O. Box 14720, Minneapolis, MN 55414 (for Plaintiff); 

Andrew T. Jackola and Robert I. Yount, Assistant County Attorneys, Anoka County 
Attorney’s Office, Government Center, 2100 Third Avenue, Seventh Floor, Anoka, 
MN 55303 (for Defendants Anoka County and Anoka County Sheriff James Stuart); 

Alexander James Thillman and Ryan M. Zipf, League of Minnesota Cities, 145 
University Avenue West, St. Paul, MN 55103 (for Defendants Coon Rapids Police 
Officer Nikolas1 Oman and City of Coon Rapids2).                         






1 In the proposed Second Amended Complaint, the spelling of Officer Oman’s first name has been corrected.  (See, 
e.g., Prop. Second Am. Compl. ¶ 19, ECF No. 59-1.)                        
2 The Coon Rapids Police Department was erroneously included in the caption of the initial Complaint, and was 
removed with the filing of the Amended Complaint (ECF No. 40).  Parada v. Anoka Cty., 
332 F. Supp. 3d 1229
, 
1236 n.5 (D. Minn. 2018).                                                 
                       I. INTRODUCTION                                   
    This matter comes before the Court on Plaintiff Myriam Parada’s Motion for Leave 

to Amend Complaint and Modify the Pretrial Scheduling Order (ECF No. 59).  A hearing 
was held on July 25, 2019.  (ECF No. 73.)  Alain M. Baudry and Ian Bratlie appeared on 
behalf of Plaintiff.  Andrew T. Jackola appeared on behalf of Defendants Anoka County 
(“County”)  and  Anoka  County  Sheriff  James  Stuart  (“Sheriff  Stuart”)  (collectively, 
“County Defendants”).  Ryan Zipf appeared on behalf of Defendants Coon Rapids Police 
Officer Nikolas Oman (“Officer Oman”) and City of Coon Rapids (“City”) (collectively, 

“City Defendants”).                                                       
                       II. BACKGROUND                                    
    Plaintiff is a citizen of Mexico and lives in Ramsey, Minnesota.  (Proposed Second 
Am. Compl. ¶ 13.)  Plaintiff entered the United States legally as a child.  (Id.)  On July 25, 
2017, Plaintiff was rear-ended by a Caucasian driver while driving some family members 

home from a birthday party.  (Id. ¶¶ 23, 26.)  Plaintiff called her parents, who came to the 
scene.  (Id. ¶ 27.)  The other driver called the police, and Officer Oman responded.  (Id. 
¶ 28.)  Officer Oman permitted the other driver, who “had 12 convictions for traffic 
violations since 2012 including DWI, speeding and obstructing the legal process,” to leave 
without a citation.  (Id. ¶¶ 30, 31.)                                     

    Officer Oman asked Plaintiff for her driver’s license.  (Id. ¶ 33.)  Plaintiff “did not 
have a Minnesota driver’s license,” and instead “gave him her proof of insurance and a 
Mexican Consular card, commonly referred to as a Matricula Consular card.”  (Id. ¶ 34.)  
“The Matricula Consular card is an official identification card issued by the Mexican 
consulate.”  (Id.)  Plaintiff’s “Matricula Consular card listed her full name, date of birth 
and address in the United States”; included “a recent photo of her”; and contained “security 

features  to  ensure  its  authenticity.”    (Id.  ¶  35.)    Plaintiff  confirmed  that  all  of  the 
information on her Matricula Consular card was accurate.  (Id. ¶ 36.)     
    Plaintiff’s step-father also confirmed the information was accurate and that he was 
the registered owner of the car.  (Id. ¶ 37.)  Plaintiff’s step-father gave Officer Oman “a 
copy of his Minnesota driver’s license.”  (Id.)  “The address on Plaintiff’s Matricula 
Consular card was the same address as Plaintiff’s step-father’s Minnesota driver’s license.”  

(Id. ¶ 38.)  “[T]he VIN number in the Department of Motor Vehicles database of a [car] 
registered . . . . [to Plaintiff’s step-father] matched the VIN number on the proof of 
insurance card in the glove compartment of the car [Plaintiff] was driving.”  (Id.)  Officer 
Oman “ran the name of Plaintiff’s step-father through his database.”  (Id. ¶ 39.) 
    Officer Oman “then spoke with Anoka [C]ounty staff on his personal phone inside 

his car for several minutes.”  (Id. ¶ 40.)  When Officer Oman returned, “he told [Plaintiff] 
that his supervisor told him to bring her in to get her prints,” and “‘I need to make sure who 
you are.’”  (Id. ¶¶ 41-42.)  Plaintiff was arrested and taken to the Anoka County Jail.  (Id. 
¶ 44.)  In a report, Officer Oman “wrote . . . that he ‘transported [Plaintiff] to jail since I 
was also unable to positively identify her.’”  (Id. ¶ 45.)                

    Officer Oman brought Plaintiff to the Anoka County Jail around 7:20 p.m.  (Id. 
¶ 50.)  At the Anoka County Jail, Officer Oman completed an “Authority to Detain” form, 
listing Plaintiff’s name, address, and date of birth as provided at the scene.  (Id. ¶ 51.)  
There was no indication that Officer Oman did not know who Plaintiff was.  (Id.)  The 
“Authority  to  Detain”  form  contains  “a  section  entitled  ‘Reason  for  Detention  for 
Misdemeanors,’” and has boxes to check to indicate that the person is not eligible for 

immediate release.  (Id. ¶ 52.)  Officer Oman did not check any of these boxes “and did not 
make any notations which would suggest that [Plaintiff] was not eligible for immediate 
release.”  (Id.)  Records indicate that Plaintiff “was placed into custody and handed over to 
the Jail only because of a citation for driving without a [Minnesota] driver’s license.”  (Id. 
¶ 51.)                                                                    
    At the Anoka County Jail, Plaintiff was handcuffed, patted down, photographed, 

and placed in a cell.  (Id. ¶¶ 53, 55, 56.)  Records indicate that Plaintiff was cleared and 
free to leave the same day.  (Id. ¶ 59; see id. ¶ 62.)  In an e-mail to Plaintiff’s counsel, 
Lieutenant  Sheila  Larson  with  the  Anoka  County  Sheriff’s  Office  explained  that 
“‘[Plaintiff] was arrested for a Misdemeanor tag/ticket charge, which means she would 
then be processed for release and given a copy of the tag.  There are a few targeted 

misdemeanors that would require us to hold her until seen by a judge, she was not brought 
in for one of those types of Misdemeanors.’”  (Id. ¶ 59.)                 
    Plaintiff was not, however, released on July 25.  (See id. ¶ 64.)  At approximately 
11:00 p.m., Plaintiff was brought to an unidentified County staff member, the unknown 
County Defendant, “who questioned her for a few minutes and then brought her back to 

her cell.”  (Id. ¶ 67.)  About half an hour later, Plaintiff was again brought to see the 
unknown County Defendant, who “handed [her] a phone and instructed [her] to talk to the 
person on the other end.”  (Id. ¶¶ 68, 69.)                               
    On the other end of the line were agents with United States Immigration and 
Customs Enforcement (“ICE”).  (Id. ¶ 70.)  ICE asked Plaintiff if she was a United States 
citizen and how she arrived in the United States.  (Id.)  Plaintiff asked the unknown County 

Defendant if she needed a lawyer, and was told to ask ICE.  (Id. ¶¶ 71, 72.)  ICE told 
Plaintiff “that ‘it goes faster without a lawyer.’”  (Id. ¶ 73.)  Plaintiff then told ICE “how 
she entered the United States.”  (Id. ¶ 74.)  After Plaintiff was done speaking with ICE, the 
unknown  County  Defendant  took  her  back  to  her  cell.    (Id.  ¶  75.)    Plaintiff  was 
fingerprinted approximately an hour later.  (Id.)                         
    In the early morning hours of July 26, ICE sent an I-200 Warrant for Arrest of an 

Alien (“ICE Warrant”) and I-247 ICE Detainer (“ICE Detainer”) to the Anoka County Jail.  
(Id. ¶¶ 76, 77, 93.)  The ICE Warrant was unsigned and not served on Plaintiff.  (Id. ¶¶ 76, 
94, 104.)  The ICE Detainer was stamped “Draft Not Complete” on each page and also not 
served on Plaintiff.  (Id. ¶¶ 77, 104.)  Around 2:00 a.m., Plaintiff was brought out of her 
cell, given a citation for not having a Minnesota driver’s license, and handed over to two 

ICE agents.  (Id. ¶¶ 81, 82.)  Plaintiff was handcuffed, shackled, and taken to the Sherburne 
County Jail.  (Id. ¶ 84.)  About an hour later, Plaintiff’s family was informed that she was 
in ICE custody.  (Id. ¶ 85.)  Plaintiff is currently in removal proceedings.  (Id. ¶ 87.) 
    Among others, Plaintiff brings claims against Defendants pursuant to 
42 U.S.C. § 1983
 for violations of her constitutional rights and false imprisonment under Minnesota 

common law.                                                               
                     III. MOTION TO AMEND                                

    Plaintiff requests leave to amend the Amended Complaint to seek punitive damages 
in connection with her federal § 1983 claims and common-law false-imprisonment claim.  
Plaintiff also seeks leave to add a § 1983 claim for violation of her equal-protection rights 
under the Fourteenth Amendment against the County Defendants.             
    A. Legal Standard                                                    
    With the exception of amendments as a matter of course, the Federal Rules of Civil 
Procedure permit a party to “amend its pleadings only with the opposing party’s written 

consent or the court’s leave.”  Fed. R. Civ. P. 15(a)(2).  The Rules further provide that 
leave should be freely given “when justice so requires.”  Id.  There is, however, “no 
absolute right to amend” and a finding of undue delay, bad faith, dilatory motive, undue 
prejudice to the non-moving party, or futility may be grounds to deny a motion to amend.  
Doe v. Cassel, 
403 F.3d 986, 990-91
 (8th Cir. 2005).  “Fundamentally, ‘the grant or denial 

of an opportunity to amend is within the discretion of the District Court.’”  Ash v. Anderson 
Merchandisers, LLC, 
799 F.3d 957, 963
 (8th Cir. 2015) (quoting Foman v. Davis, 
371 U.S. 178, 182
 (1962)).                                                         
    B. Equal-Protection Claim Against the County Defendants              
    The Court begins with Plaintiff’s proposed § 1983 claim for violation of her equal-

protection rights under the Fourteenth Amendment against the County Defendants. 
         1.  Good Cause                                                  
    With the exception of motions to seek punitive damages, the deadline for motions 
to amend the pleadings was December 15, 2018.  (ECF No. 56 at 3.)  As Plaintiff’s motion 
was filed after that deadline, Plaintiff must show good cause for modification of the 
deadline.  Sherman v. Winco Fireworks, Inc., 
532 F.3d 709, 716-17
 (8th Cir. 2008).  “The 

primary measure of good cause is the  movant’s diligence in attempting  to  meet the 
scheduling order’s requirements.”  Harris v. FedEx Nat’l LTL, Inc., 
760 F.3d 780, 786
 (8th 
Cir. 2014) (quotation omitted); see also Sherman, 
532 F.3d at 716-17
.  “The ‘good cause’ 
standard is an exacting one, for it demands a demonstration that the existing schedule 
cannot reasonably be met despite the diligence of the party seeking the extension.”  Khoday 
v. Symantec Corp., No. 11-cv-180 (JRT/TNL), 
2013 WL 12141434
, at *2 (D. Minn. May 

15, 2013) (quotation omitted).                                            
    Plaintiff asserts that she discovered the basis for her proposed equal-protection 
claim against the County Defendants during a 30(b)(6) deposition of the County, which 
took place on June 18, 2019.  The County appeared through Commander David Pacholl.3  
During the deposition, Commander Pacholl testified that the Anoka County Jail notifies 

ICE as part of its booking procedure when an individual identifies him or herself as having 
been born outside of the United States, states that he or she is not a United States citizen or 
is a foreign national, or provides “data” from another country.  (Dep. of David Pacholl 
160:12-169:1, Ex. 4 to Aff. of Amanda Cefalu, ECF No. 60-4.)  Commander Pacholl 
testified that there is an automated, law-enforcement electronic communication program 

through which ICE is notified, and the Anoka County Jail may also follow up with ICE via 
telephone if a response is not received in connection with the automated notification.  


3 At the hearing, counsel for the County Defendants stated that Commander Pacholl is the highest ranking official 
for the Anoka County Jail.                                                
(Pacholl Dep. 163:1-165:13.)  It is this automatic notification to ICE that forms the basis 
of Plaintiff’s proposed equal-protection claim.  See infra Section III.B.2.b.   

    The County Defendants respond that parties have been engaged in discovery for 
nearly a year, and Plaintiff could have taken this deposition sooner.  They additionally 
respond that, with little time left for fact discovery, it “is too late” for Plaintiff “to inject a 
new theory of liability” into this case.  (County Opp’n at 14, ECF No. 68.)  At the hearing, 
the Court inquired as to whether the existing pretrial schedule would need to be amended 
should Plaintiff be permitted to add this claim.  Plaintiff and the County Defendants each 

confirmed that no adjustments would be needed.                            
    The  Court  finds  that  Plaintiff  has  been  diligent  in  attempting  to  meet  the 
requirements of the scheduling order.  Plaintiff reasonably pursued information regarding 
the County Defendants’ policies and communications with ICE through other discovery 
methods during the fact discovery period, and learned of the automatic notification process 

during a 30(b)(6) deposition taken more than two months before the close of fact discovery.  
Once she became aware of the automatic notification process, Plaintiff promptly moved to 
amend.  Further, having found that Plaintiff was diligent in meeting the requirements of 
the scheduling order, it is also relevant the County Defendants have not articulated any 
specific prejudice resulting from the timing of the amendment.  As stated above, Plaintiff 

and the County Defendants agree that, if granted, the proposed amendment would not affect 
any of the existing deadlines.  Accordingly, Plaintiff has shown good cause to seek leave 
to amend past the December 15, 2018 deadline.                             
         2.  Futility of the Amendment                                   

    The  County  Defendants  oppose  Plaintiff’s proposed  equal-protection  claim  on 
grounds that it is futile.                                                
              a.  Legal Standard                                         
    “Futility  is  a  well-recognized  basis  for  denying  a  proposed  amendment.”  
ecoNugenics, Inc. v. Bioenergy Life Sci., Inc., 
355 F. Supp. 3d 785, 793
 (D. Minn. 2019) 
(citing Foman, 
371 U.S. at 182
); see, e.g., Lansing v. Wells Fargo Bank, N.A., 
894 F.3d 967, 973-74
 (8th Cir. 2018) (“[A] district court properly denies leave when a proposed 

amendment would be futile.”); Munro v. Lucy Activewear, Inc., 
899 F.3d 585, 589
 (8th Cir. 
2018)  (“However,  futility  is  a  valid  basis  for  denying  leave  to  amend.”  (quotation 
omitted)).  “An amendment is futile if the amended claim could not withstand a motion to 
dismiss under Rule 12(b)(6).”  Hillesheim v. Myron’s Cards & Gifts, Inc., 
897 F.3d 953, 955
 (8th Cir. 2018) (quotation omitted); accord Cornelia I. Crowell GST Tr. v. Possis 

Med., Inc., 
519 F.3d 778, 782
 (8th Cir. 2008) (“[W]hen the court denies leave on the basis 
of futility, it means the district court has reached the legal conclusion that the amended 
complaint could not withstand a motion to dismiss under Rule 12(b)(6) of the Federal Rules 
of Civil Procedure.”).                                                    
    “To withstand a Rule 12(b)(6) motion, a complaint must contain sufficient factual 

allegations to ‘state a claim to relief that is plausible on its face.’”  Smithrud v. City of St. 
Paul, 
746 F.3d 391, 397
 (8th Cir. 2014) (quoting Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 547
 (2007)).  “A claim has facial plausibility when the plaintiff pleads factual content that 
allows the court to draw the reasonable inference that the defendant is liable for the 
misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (citing Twombly, 
550 U.S. at 556
).  “[A]lthough a complaint need not contain ‘detailed factual allegations,’ it 

must contain facts with enough specificity ‘to raise a right to relief above the speculative 
level.’”  U.S. ex rel. Raynor v. Nat’l Rural Utils. Coop. Fin., Corp., 
690 F.3d 951, 955
 (8th 
Cir. 2012) (quoting Twombly, 
550 U.S. at 555
).  “A pleading that offers ‘labels and 
conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’”  
Iqbal, 
556 U.S. at 678
 (quoting Twombly, 
550 U.S. at 555
).  Similarly, “[t]hreadbare 
recitals of the elements of a cause of action, supported by mere conclusory statements, do 

not suffice.”  
Id.
  “In deciding a motion to dismiss under Rule 12(b)(6), a court assumes all 
facts in the complaint to be true and construes all reasonable inferences most favorably to 
the complainant.”  Raynor, 
690 F.3d at 955
.                               
              b.  Allegations                                            

    Plaintiff’s proposed equal-protection claim is based on the County Defendants 
automatically notifying ICE whenever a person born outside of the United States is brought 
to the Anoka County Jail and selectively detaining foreign-born persons who are otherwise 
eligible for release.4  The district court previously articulated the elements of an equal-


4 Plaintiff inconsistently refers to the class of individuals she alleges were subject to differing treatment.  
Throughout Plaintiff’s pleadings and in her memorandum in support of the instant motion, Plaintiff appears to refer 
to the same class of individuals interchangeably as “foreign-born” persons and “noncitizens.”  Such terms are not 
interchangeable.  While an individual may fall into both categories, an individual may also be born outside of the 
United States and still be a citizen of the United States.  More often than not, Plaintiff uses the term “noncitizens.”  
(Compare, e.g., Proposed Second Am. Compl. ¶¶ 130, 192, 195, A-C (foreign-born) with ¶¶ 65, 66, 160-162, 165 
(noncitizen) with ¶¶ 6, 119 (use of both); Pl.’s Mem. in Supp. passim (use of noncitizen, not foreign-born).)  At the 
hearing, the Court sought clarification as to the class of individuals to which Plaintiff is referring.  Plaintiff’s counsel 
stated that the class of individuals at issue were people born outside of the United States, i.e., foreign-born, not 
noncitizens.  Based on the representation of Plaintiff’s counsel, the Court uses the term “foreign-born.”  See infra 
n.7.                                                                      
protection claim based on selective enforcement:                          
         Immigrants−even if unlawfully present−are protected by the      
         Equal Protection Clause.  Plyler v. Doe, 
457 U.S. 202, 210
, 
102 S. Ct. 2382
,  
72 L.Ed.2d 786
  (1982).    “[T]he  Constitution 
         prohibits  selective  enforcement  of  the  law  based  on      
         considerations such as race.”  Whren v. United States, 
517 U.S. 806, 813
, 
116 S. Ct. 1769
, 
135 L.Ed.2d 89
 (1996).  A selective- 
         enforcement claim does not require proof that the plaintiff was 
         arrested without probable cause or reasonable suspicion to      
         believe  that  the  plaintiff  committed  a  criminal  offense.  
         Johnson v. Crooks, 
326 F.3d 995, 999-1000
 (8th Cir. 2003).      
         Rather, the plaintiff must prove that the officer exercised his or 
         her discretion to enforce the laws on account of the plaintiff's 
         race, nationality, or other characteristics.  See 
id. at 1000
.  
         “When the claim is selective enforcement of the traffic laws or 
         a racially-motived arrest, the plaintiff must normally prove that 
         similarly situated individuals were not stopped or arrested in  
         order to show the requisite discriminatory effect and purpose.”  
         
Id.
                                                             

Parada, 
332 F. Supp. 3d at 1244
.                                          
    Plaintiff alleges that the County Defendants “acted pursuant to an unwritten policy, 
custom, or pattern or practice to engage in discrimination on the basis of national origin or 
ethnicity by automatically contacting ICE any time a [foreign-born person] is brought to 
the Anoka County [Jail].”  (Proposed Second Am. Compl. ¶ 160; see Proposed Second 
Am. Compl. ¶ 65.)  Plaintiff further alleges that the County Defendants detain foreign-born 
persons who are otherwise eligible for release longer than similarly-situated individuals, 
namely, until ICE arrives, thereby discriminating against foreign-born persons based on 
their national origin and/or ethnicity.  (Proposed Second Am. Compl. ¶¶ 65, 161-62, 165.)  
Plaintiff also alleges that the County Defendants “have intentionally targeted Hispanic 
individuals who are brought to the Anoka County [J]ail to be subject to unlawful detention 
and turnover to ICE.”  (Proposed Second Am. Compl. ¶ 164.)                
    The County Defendants complain that Plaintiff has not articulated how this “class” 

of persons allegedly subject to different treatment “has been or continues to suffer a harm 
associated with their distinct treatment,” arguing that “the claim is suspect because who 
else, besides non-citizens, would be subject to the jurisdiction of ICE for purposes of 
checking immigration status.”  (County Opp’n at 15.)  Plaintiff’s proposed equal-protection 
claim is not, however, solely grounded in the County Defendants’ communications with 
ICE.  Plaintiff has alleged that foreign-born persons who are otherwise eligible for release 

are detained longer than other individuals otherwise eligible for release based on their race, 
nationality, and perceived immigration status.  The harm alleged is the prolonged detention 
of a foreign-born person who is otherwise eligible for release.  The remainder of the County 
Defendants’ arguments go to the merits of Plaintiff’s proposed equal-protection claim and 
not to whether Plaintiff has stated a claim.                              

    Here, Plaintiff has plausibly alleged that (1) she was eligible for release but detained 
on account of her race, nationality, and perceived immigration status; (2) the County 
Defendants acted pursuant to an unwritten policy, custom, pattern or practice to engage in 
racial profiling, and (3) other similarly situated individuals eligible for release were not 
subject to such detention.  See Parada, 
332 F. Supp. 3d at 1245
.  Plaintiff’s proposed equal-

protection claim against the County Defendants is not futile, and therefore the Court will 
grant Plaintiff’s motion with respect to this claim.                      
    C. Punitive Damages                                                  

    Plaintiff also seeks leave to include a request for punitive damages in connection 
with her federal § 1983 claims and common-law, false-imprisonment claim.  At the 
hearing, Plaintiff clarified that she is only seeking punitive damages against Officer Oman 
and  Sheriff  Stuart  individually,  not  in  their  official  capacities,  and  not  against  the 
governmental entities.  Plaintiff’s motion to add punitive damages is timely. 
         1.  § 1983 Claims                                               

    A request to add punitive damages in connection with a claim brought pursuant to 
42 U.S.C. § 1983
 is governed by Rule 15 of the Federal Rules of Civil Procedure.  Le-Vert-
Woitalla v. Carver Cty., No. 11-cv-238 (JRT/JJK), 
2011 WL 13233268
, at *5 (D. Minn. 
July 7, 2011).  While the City Defendants do not concede that Plaintiff is entitled to recover 
punitive damages in connection with her § 1983 claims against Officer Oman in his 
individual capacity, they do not object to Plaintiff’s request to seek such damages.  The 

County Defendants object to the inclusion of a request for punitive damages against Sheriff 
Stuart on grounds that he was not personally involved in the events in question and is not 
liable on Plaintiff’s claims.                                             
    “Punitive damages may be awarded under 
42 U.S.C. § 1983
 ‘when the defendant’s 
conduct is shown to be motivated by evil motive or intent, or when it involves reckless or 

callous indifference to the federally protected rights of others.’”  Schaub v. VonWald, 
638 F.3d 905, 922
 (8th Cir. 2011) (quoting Smith v. Wade, 
461 U.S. 30, 56
 (1983)); accord 
Washington  v.  Denney,  
900 F.3d 549, 563-64
  (8th  Cir.  2018).    “Proving  reckless 
indifference requires evidence that the defendant acted in the face of a perceived risk that 
his or her actions would violate federal law.”  McAdoo v. Martin, 
899 F.3d 521, 527
 (8th 
Cir. 2018) (quotation omitted).  “Punitive damages punish a defendant for outrageous, 

intentional, or malicious conduct, and deter similar extreme conduct in the future.”  Schaub, 
638 F.3d at 922-23
 (footnote omitted).  “It is a question of fact whether a defendant’s 
conduct was motivated by an evil motive or involves reckless indifference to the federally 
protected rights of others.”  
Id. at 923
.  Thus, “[w]hile an award of compensatory damages 
is mandatory upon a finding of liability, punitive damages are awarded or rejected in a 
particular case at the discretion of the factfinder once sufficiently serious misconduct by 

the defendant is shown.”  Washington, 
900 F.3d at 563
 (quotation omitted).  “The factfinder 
focuses on the defendant’s intent in determining whether to award punitive damages and 
whether the defendant’s conduct is of the sort that calls for deterrence and punishment over 
and above that provided by compensatory awards.”  
Id. at 563-64
 (quotation omitted). 
    The County Defendants are essentially asking this Court to render a dispositive 

ruling on the merits of Plaintiff’s claims.  Yet, the County Defendants did not challenge 
the sufficiency of Plaintiff’s existing § 1983 claims in a motion to dismiss and, as stated 
above, the Court has concluded that Plaintiff’s proposed equal-protection allegations state 
a claim.  Punitive damages are authorized in connection with § 1983 claims.  See, e.g., 
Schaub, 
638 F.3d at 922
; Le-Vert-Woitalla, 
2011 WL 13233268
, at *5.  The County 

Defendants can argue at a more procedurally appropriate juncture the merits of their 
position, including fundamental questions of liability and whether the evidence supports a 
finding of evil motive, intent, or reckless or callous indifference to the federally protected 
rights of others.                                                         
    Therefore, Plaintiff’s motion is granted with respect to her § 1983 claims, and she 
may amend the Amended Complaint to seek punitive damages against Officer Oman and 

Sherriff  Stuart  in  their  individual  capacities  in  connection  with  her  §  1983  claims.  
Consistent with this ruling, the Court will permit the inclusion of the proposed additional 
factual allegations.                                                      
         2.  False-Imprisonment Claim                                    

    Plaintiff also seeks leave to pursue punitive damages against Officer Oman and 
Sheriff Stuart in connection with her common-law false imprisonment claim.  Plaintiff has 
presented her arguments under 
Minn. Stat. §§ 549.191
 and 549.20.  (Pl.’s Mem. in Supp. 
at 12-14, ECF No. 77; see Pl.’s Mem. in Supp. at 19-20.)  Accordingly, the Court proceeds 
thereunder.  Cf. Shank v. Carleton College, No. 16-cv-1154 (PJS/HB), 
2018 WL 4961472
, 
at *4 (D. Minn. Oct. 15, 2018).                                           
              a.  Legal Standard                                         

    Under Minnesota law, a party must move for leave to amend the pleadings to include 
punitive damages.  
Minn. Stat. § 549.191
; Olson v. Snap Prods., Inc., 
29 F. Supp. 2d 1027, 1034
 (D. Minn. 1998).  “The motion must allege the applicable legal basis under [§] 549.20 
or other law for awarding punitive damages in the action and must be accompanied by one 
or more affidavits showing the factual basis for the claim.”  
Minn. Stat. § 549.191.5
  “[I]f 


5 At the hearing, Plaintiff presented a collection of 14 exhibits to the Court in support of her motion (“Hearing 
Exhibits”).  Some of the Hearing Exhibits were duplicative of exhibits attached to the affidavit of Amanda Cefalu 
filed in support of Plaintiff’s motion.  These duplicative exhibits include: Plaintiff’s Matricula Consular card (Ex. 1 
to Cefalu Aff., ECF No. 60-1; Hearing Ex. 1); the preliminary expert report of Roy Bedard (Ex. 2 to Cefalu Aff., 
ECF No. 60-2; Hearing Ex. 9); the Authority to Detain Form (Ex. 3 to Cefalu Aff., ECF No. 60-3 at 2; Hearing Ex. 
8); Officer Oman’s incident report (Ex. 3 to Cefalu Aff., ECF No. 60-3 at 3; Hearing Ex. 7); excerpts from 
Commander Pacholl’s 30(b)(6) deposition (Ex. 4 to Cefalu Aff., ECF No. 60-4 at 2-15; Hearing Ex. 11); e-mail 
correspondence on April 17, 2017, between Commander Pacholl and Bryan R. Lindberg (Ex. 4 to Cefalu Aff., ECF 
the court finds prima facie evidence in support of the motion, the court shall grant the 
moving party permission to amend the pleadings.”  
Id.
                     

    Punitive damages are permitted “only upon clear and convincing evidence that the 
acts of the defendant show deliberate disregard for the rights or safety of others.”  
Minn. Stat. § 549.20
, subd. 1(a).                                               
         A defendant has acted with deliberate disregard for the rights  
         or safety of others if the defendant has knowledge of facts or  
         intentionally disregards facts that create a high probability of 
         injury to the rights or safety of others and:                   

              (1)  deliberately  proceeds  to  act  in  conscious  or    
         intentional disregard of the high degree of probability of injury 
         to the rights or safety of others; or                           

              (2) deliberately proceeds to act with indifference to the  
         high probability of injury to the rights or safety of others.   

Id.,
 subd. 1(b).  “Clear and convincing evidence is more than a preponderance of the 

No. 60-4 at 19-20; Hearing Ex. 12); and a January 5, 2018 e-mail from Lieutenant Larson to Plaintiff’s counsel (Ex. 
4 to Cefalu Aff., ECF No. 60-4 at 21; Hearing Ex. 10).  Hearing Exhibits 2 and 3 were not filed in connection with 
the instant motion, but appear to have been previously filed as part of Plaintiff’s opposition to the City Defendants’ 
motion to dismiss.  But see Parada, 
332 F. Supp. 3d at 1238
 (declining to consider evidence submitted outside of the 
pleadings on motion under Fed. R. Civ. P. 12(b)(6)).  Hearing Exhibit 2 is the insurance card of Plaintiff’s 
stepfather.  (ECF No. 22-2.)  Hearing Exhibit 3 is the Minnesota driver’s license of Plaintiff’s stepfather.  (ECF No. 
26.)  Hearing Exhibit 6 is a copy of a PATROL (“Police Accredited TRaining OnLine” [sic]) course summary for 
misdemeanor arrests, which was appears to be training that was provided to Officer Oman.  A single page 
(CR000015) of this three-page (CR000013-15) summary was attached to Plaintiff’s preliminary expert report.  (Ex. 
2 to Cefalu Aff., ECF No. 60-2 at 6.)                                     
    Hearing Exhibits 4, 5, 13, and 14 were presented for the first time at the hearing.  At the hearing, Plaintiff’s 
counsel explained that Hearing Exhibit 4 is the information returned when Officer Oman ran the car Plaintiff was 
driving.  Hearing Exhibit 5 was described as an example of information returned if someone were to perform an 
Internet search for “Matricula Consular,” which Plaintiff’s expert opined “[a] curious officer could . . .” do.  (Ex. 60-
2 at 3.)  Hearing Exhibit 13 is a copy of the district judge’s ruling on the City Defendants’ motion to dismiss.  
Hearing Exhibit 14 contains excerpts from the July 24, 2019 depositions of Lieutenant Larson and Wayne Heath.  
These depositions were taken the day before the hearing and the transcript excerpts provided to the Court are 
uncertified, rough drafts.                                                
    At the hearing, the Court expressed frustration with such after-the-fact submissions, presented on the day of 
the hearing, after briefing had been complete.  The Court also expressed reservations about the use of uncertified, 
unofficial transcripts, and Plaintiff agreed to proceed without them.  Plaintiff shall file Hearing Exhibits 4, 5, and 6 
within 7 days from the date of this Order.                                
evidence but less than proof beyond a reasonable doubt.”  In re Levaquin Prods. Liab. 
Litig., MDL No. 08-1943 (JRT), No. 08-cv-5743 (JRT), 
2010 WL 7852346
, at *5 (D. 

Minn. Nov. 9, 2010) (quotation omitted); accord Olson, 
29 F. Supp. 2d at 1036
.  Olson 
instructs that this standard is satisfied when “the evidence is sufficient to permit the Jury 
to conclude that it is ‘highly probable’ that the defendant acted with deliberate disregard to 
the rights or safety of others.”  
29 F. Supp. 2d at 1036
 (quotation omitted). 
    At this stage, “[a] plaintiff need not demonstrate an entitlement to punitive damages 
per se, but only an entitlement to allege such damages.”  Berczyk v. Emerson Tool Co., 
291 F. Supp. 2d 1004, 1008
 (D. Minn. 2003) (footnote omitted); accord In re Levaquin Prods. 
Liab. Litig., 
2010 WL 7852346
, at *6.  Under Minnesota law, “‘prima facie’ does not refer 
to  a  quantum  of  evidence”;  rather,  “prima  facie  evidence  is  that  evidence  which, if 
unrebutted, would support a judgment in that party’s favor.”  Olson, 
29 F. Supp. 2d at 1034
 
(quotations omitted).  The Court does not make any credibility determinations or consider 

challenges to the evidence when determining whether a prima facie showing has been 
made.  Freeland v. Fin. Recovery Servs., Inc., 
790 F. Supp. 2d 991, 994
 (D. Minn. 2011).  
Nevertheless, “when presented with a [m]otion for leave to assert a punitive damage claim, 
the function of the Court is to do more than ‘rubber stamp’ the allegations in the [m]otion 
papers.”  Ulrich v. City of Crosby, 
848 F. Supp. 861, 868
 (D. Minn. 1994).  “[T]he Court 

must carefully scrutinize the evidence presented by the moving party to make sure that it 
amounts to a prima facie showing that the substantive requirements for punitive damages 
have been met.”  Healey v. I-Flow, LLC, 
853 F. Supp. 2d 868, 873
 (D. Minn. 2012); see 
Ulrich, 
848 F. Supp. at 868-69
.                                           
              b.  Elements of False Imprisonment                         
    “The tort of false imprisonment or false arrest protects the personal interest in 

freedom from restraint of movement.”  Strei v. Blaine, 
996 F. Supp. 2d 763, 789
 (D. Minn. 
2014) (quotation omitted); see also Riehm v. Engelking, 
538 F.3d 952, 969
 (8th Cir. 2008) 
(“According  to  Minnesota  common  law,  [a]n  individual  may  not,  without  legal 
justification, be confined against his or her will.” (quotation omitted)).  “An arrest made 
without proper legal  authority is a false arrest, and  any subsequent restraint is false 
imprisonment.”  Binion v. City of St. Paul, 
788 F. Supp. 2d 935, 949
 (D. Minn. 2011) 

(quotation  omitted);  accord  Strei,  
996 F. Supp. 2d at 789
.    “To  establish  a  false-
imprisonment claim against law enforcement, the plaintiff must prove that defendants 
performed an arrest and the arrest was unlawful.”  Parada, 
332 F. Supp. 3d at 1246
. 
                  i.  Officer Oman                                       
    Plaintiff argues that “there is evidence from which it may be inferred that Officer 

Oman was never in doubt about [her] true identity, and made no attempt to consider relying 
on the available corroboration,” and that a reasonable jury could conclude that Officer 
Oman “intentionally imprisoned [her] on false pretenses for the purpose of getting ICE 
involved.”  (Pl.’s Mem. in Supp. at 20-21.)                               
    Plaintiff has presented evidence that Officer Oman had before him several pieces of 

information corroborating her identity.  These included her Matricula Consular card, the 
insurance card, the driver’s license of her stepfather, and the results of the search Officer 
Oman ran on the car she was driving.  Plaintiff has also presented evidence in the form of 
a preliminary expert report that, along with her self-identification and her stepfather’s 
verbal identification, a reasonable officer would have accepted the information provided 
by Plaintiff and concluded that she was who she said she was and resided at the address 

shown.                                                                    
    As to Plaintiff’s allegation that Officer Oman was “motivated by anti-immigrant 
animus,” Plaintiff states that she “discovered . . . [that Officer] Oman issued at least six 
citations for no Minnesota driver’s license in the last year without arresting the individuals 
and taking them into custody,” and “liked” two individuals and a news organization on 
social media, which “have publicly professed strongly anti-immigrant views. ”  (Pl.’s Mem. 

in Supp. at 10-11.)  Plaintiff further states,                            
         upon  information  and  belief,  that based  upon  his  years  of 
         working for the [City’s] Police Department, and his numerous    
         interactions  with  the  Anoka  County  Jail  and  Sheriff’s    
         department, Officer Oman was aware of [the County’s] policy     
         or  practice  of  automatically  contacting  ICE  when  non-US  
         citizens were brought to the Anoka County [J]ail and thus that  
         [she] would come to the attention of ICE by virtue of his       
         decision to detain her.                                         

(Pl.’s Mem. in Supp. at 17.)  Yet, Plaintiff has not presented evidence of situations where 
Officer Oman previously issued citations to, rather than arresting, an individual without a 
Minnesota driver’s license.  Plaintiff has not presented evidence that Officer Oman was 
aware that the County would contact ICE as part of its booking process.  Nor has Plaintiff 
presented evidence of Officer Oman’s tenure with the City’s police department or his prior 
interactions with the Anoka County Jail and County Defendants.            
    With respect to social media, Plaintiff has not presented evidence from which a jury 
could reasonably infer that Officer Oman was motivated by—or even has—anti-immigrant 
views.  Plaintiff has attached a print-out from Officer Oman’s Facebook page, showing 
that Officer Oman has “liked” more than 160 social media sites, including restaurants, 

automobile manufactures, public figures, law enforcement agencies, news organizations, 
and sporting goods retailers, among others.  (Ex. 5 to Cefalu Aff., ECF No. 60-5.)  Of these, 
Plaintiff singles out three and states these two individuals and a news organization have 
expressed anti-immigrant views.  Other than excerpting a quote from a news article without 
including the article itself, Plaintiff has not presented evidence regarding the purported 
anti-immigrant views of one of these individuals.  Plaintiff has not presented evidence 

regarding the news organization other than to state that it aired a program on which the 
second individual appeared.  As for the second individual, Plaintiff has included an article 
which quotes statements the second individual made during the program aired by the news 
organization.  But, even assuming these two individuals and the news organization at one 
point or another expressed anti-immigrant views, there is no evidence in the record that 

Officer Oman shares or endorses these views.  There is no evidence in the record as to why 
Officer  Oman  “liked”  the  social  media  sites  of  these  two  individuals  and  the  news 
organization.  Plaintiff is asking this Court to engage in pure speculation as to Officer 
Oman’s interest in these three social media sites.6                       
    Plaintiff also purports to rely the district court’s ruling on the City Defendants’ 

motion to dismiss as evidence that her arrest was pretextual.  The district court, however, 
was commenting on the sufficiency of Plaintiff’s allegations and whether she had stated a 


6 To say nothing of the complicated potential First Amendment issues that may arise in connection with presumed 
imputations of invidiousness based on what news or social media one follows. 
claim, not evidence.  In fact, the district court acknowledged that evidence had been 
submitted outside of the pleadings in connection with the motion to dismiss, but expressly 

“exclude[d] the submitted evidence and . . . consider[ed] the motion under Rule 12(b)(6).”  
Parada, 
332 F. Supp. 3d at 1238
.  Under these circumstances, the district court’s ruling 
does not supply a factual basis to support Plaintiff’s contention that Officer Oman acted 
with deliberate disregard for her rights.                                 
    Rather than the pretextual, anti-immigrant motive Plaintiff asks the Court to infer, 
the unrebutted evidence could as easily suggest that Officer Oman was in fact unfamiliar 

with a Matricula Consular card, and brought Plaintiff in because he was not able to verify 
her identification.  See Romano v. ReliaStar Life Ins. Co., No. 12-cv-137 (SRN/JJK), 
2012 WL 5907397
, at *6 (D. Minn. Nov. 26, 2012).  While Plaintiff’s expert has opined that a 
reasonable officer would have relied on the Matricula Consular card, Plaintiff has also 
presented evidence in the form of a memorandum from the City’s chief of police, stating 

that he had “never heard of a Matricula Consular card” prior to this incident and was not 
aware “of any State Law or Court Order instructing law enforcement to accept this card as 
proof of identity.”  (Ex. 7 to Cefalu Aff., ECF No. 60-7 at 2.)  Moreover, as Plaintiff herself 
points out, Officer Oman did not check any of the exceptions to eligibility for immediate 
release “and did not make any notations which would suggest that [she] was not eligible 

for immediate release” when completing the Authority to Detain form at the Anoka County 
Jail.  (Pl.’s Mem. in Supp. at 7.)  The possibility of an innocent explanation for Officer 
Oman’s decision to arrest Plaintiff undermines her argument that she has presented prima 
facie evidence that Officer Oman acted with deliberate disregard for her rights.  See 
Romano, 
2012 WL 5907397
, at *6; see also Smith v. Morales, No. A07-2377, 
2008 WL 4909630
, at *4-5 (Minn. Ct. App. Nov. 18, 2008).                          

    At best, Plaintiff has presented evidence that Officer Oman may have been negligent 
in not relying on her Matricula Consular card and other corroborating information.  But 
negligence, even gross negligence, is not enough to rise to the level of deliberate disregard 
for the rights of another.  See Freeland, 
790 F. Supp. 2d at 994-95
; Berczyk, 
291 F. Supp. 2d at 1008
; Olson, 
29 F. Supp. 2d at 1035
.  And, the fact that Plaintiff’s arrest may have 
been improper is not by itself sufficient to sustain a request for punitive damages.  Ward v. 

Nat’l  Car  Rental  Sys.,  
290 N.W.2d 441, 443
  (Minn.  1980);  see  Porter  v.  City  of 
Minneapolis, No. 13-cv-2499 (MJD/FLN), 
2014 WL 12607719
, at *4 (D. Minn. Sept. 29, 
2014). Section 549.191 “requires more than the presentation of evidence that is simply 
consistent with a plaintiff’s claim.  Th[is] gatekeeping statute requires prima facie evidence 
that clearly and convincingly suggests a deliberate disregard for the plaintiff’s rights.”  

Romano,  
2012 WL 5907397
,  at  *6.    While  “[a]  plaintiff  may  appropriately  rely  on 
inferences that can be drawn from other evidence in the record . . . if that evidence clearly 
and convincingly suggests an inference of deliberate disregard of the [plaintiff’s] rights,” 
the Court cannot draw such an inference with respect to Officer Oman from the evidence 
proffered by Plaintiff.  
Id. at *7
.                                       

    Based on the foregoing, the Court concludes that Plaintiff has not presented prima 
facie evidence that Officer Oman acted with deliberate disregard of her rights when he 
arrested her.  Therefore, Plaintiff’s motion is denied with respect to her request to seek 
punitive damages in connection with her false-imprisonment claim against Officer Oman. 
                 ii.  Sheriff Stuart                                     
    Plaintiff argues that Sherriff Stuart “intentionally prolong[ed] her detention,” and 

“treated [her] as an immigration detainee from the outset.”  (Pl.’s Mem. in Supp. at 20, 21.) 
    It is worth emphasizing that Plaintiff is requesting leave to pursue punitive damages 
against Sheriff Stuart in his individual capacity.  As the County Defendants point out, 
Plaintiff has not presented evidence “that Sheriff Stuart was at the jail on the night of her 
arrest or knew anything about her detention as it was happening.”  (County Opp’n at 12.)  
There is no evidence in the record that Sheriff Stuart was personally involved in Plaintiff’s 

detention at the Anoka County Jail.                                       
    Plaintiff points to evidence that Sheriff Stuart “oversees the jail,” (Pacholl Dep. 
37:11), and the County’s 30(b)(6) testimony that the Anoka County Jail relies on the 
arresting officer and the court system as to whether an arrest was lawful.  Plaintiff contends 
that “[t]his admission demonstrates that the Anoka County Sheriff accepted [her] into the 

Jail facility with no regard for whether or not Officer Oman had probable cause to arrest 
her.”  (Pl.’s Mem. in Supp. at 18.)  Plaintiff also relies on Lieutenant Larson’s January 5, 
2018  e-mail,  in  which  Lieutenant  Larson  stated  that  Plaintiff  “was  arrested  for  a 
Misdemeanor tag/ticket charge, which means she would not be held in custody once she is 
booked, she would then be processed for release and given a copy of the tag,” and that 

Plaintiff was not brought in for a type of misdemeanor that would require her to be held.  
(ECF No. 60-4 at 21.)  Plaintiff argues that this is an “admi[ssion] that [she] never should 
have been detained.”  (Pl.’s Mem. in Supp. at 8.)                         
    Again,  even  assuming  for  purposes  of  this  motion  that  Plaintiff’s  arrest  and 
detention were improper, this is not sufficient to sustain a request for punitive damages in 
connection with her false-imprisonment claim.  Ward, 
290 N.W.2d at 443
; see Porter, 
2014 WL 12607719
, at *4; see also Romano, 
2012 WL 5907397
, at *6.  And, again, Plaintiff 
has not presented evidence that Sheriff Stuart was personally involved in her detention.  
Nor has Plaintiff presented evidence showing—or even argued—that punitive damages 
should be allowed under some sort of master-and-principal theory as to any acts by other 
individuals at the Anoka County Jail.  See 
Minn. Stat. § 549.20
, subd. 2 (describing 
situations in which punitive damages may be “awarded against a master or principal 

because of an act done by an agent”).                                     
    Accordingly,  the  Court  concludes  that  Plaintiff  has  not  presented  prima  facie 
evidence that Sheriff Stuart acted with deliberate disregard of her rights, and her motion is 
likewise denied with respect to her request to seek punitive damages in connection with 
her false-imprisonment claim against Sheriff Stuart.                      

    D. Summary                                                           

    In sum, Plaintiff’s motion is granted with respect to her proposed equal-protection 
claim7 against the County Defendants and request to seek punitive damages in connection 
with  her  §  1983  claims  against  Officer  Oman  and  Sheriff  Stuart  in  their  individual 
capacities.  Plaintiff shall specify that such damages are being sought only with respect to 
these claims and in this capacity.  Plaintiff’s motion is denied with respect to her request 
to seek punitive damages in connection with her false-imprisonment claim. 


7 The Court encourages Plaintiff to verify the terminology employed.  See supra n.4. 
                           IV. ORDER                                     
    Based on the foregoing, and all of the files, records, and proceedings herein, IT IS 

HEREBY ORDERED that:                                                      
    1.  Plaintiff’s Motion for Leave to Amend Complaint and Modify the Pretrial 
      Scheduling Order (ECF No. 59) is GRANTED IN PART and DENIED IN     
      PART as set forth herein.                                          

    2.  Plaintiff shall file Hearing Exhibits 4, 5, and 6 within 7 days from the date of 
      this Order.                                                        

    3.  Plaintiff shall file a Second Amended Complaint consistent with this Order and 
      in substantially the same form as the Proposed Second Amended Complaint for 
      Damages, Punitive Damages and Other Relief (ECF No. 59-1) within 7 days 
      from the date of this Order.                                       

    4.  All prior consistent orders remain in full force and effect.     

    5.  Failure to comply with any provision of this Order or any other prior consistent 
      Order shall subject the non-complying party, non-complying counsel and/or 
      the party such counsel represents to any and all appropriate remedies, sanctions 
      and the like, including without limitation: assessment of costs, fines and 
      attorneys’ fees and disbursements; waiver of rights to object; exclusion or 
      limitation of witnesses, testimony, exhibits and other evidence; striking of 
      pleadings; complete or partial dismissal with prejudice; entry of whole or 
      partial default judgment; and/or any other relief that this Court may from time 
      to time deem appropriate.                                          




Dated: September      16    , 2019      s/ Tony N. Leung                                      
                                  Tony N. Leung                          
                                  United States Magistrate Judge         
                                  District of Minnesota                  

                                  Parada v. Anoka County et al.          
                                  Case No. 18-cv-795 (JRT/TNL)           

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Myriam Parada,                      Case No. 18-cv-795 (JRT/TNL)         

          Plaintiff,                                                     

v.                                           ORDER                       

Anoka County; Anoka County Sheriff                                       
James Stuart; Coon Rapids Police Officer                                 
Nicolas Oman; City of Coon Rapids; and                                   
Unknown/Unnamed Defendants John Doe                                      
& Jane Doe; All individuals being sued in                                
their individual and official capacity,                                  

          Defendants.                                                    


Alain M. Baudry, Saul Ewing Arnstein & Lehr LLP, 33 South Sixth Street, Suite 4750, 
Minneapolis, MN 55402; Amanda R. Cefalu and Nathan T. Boone, Kutak Rock LLP, 
60 South Sixth Street, Suite 3400, Minneapolis, MN 55402; Ian Bratlie, ACLU of 
Minnesota, 709 South Front Street, Suite 1B, Mankato, MN 56001; and Teresa J. 
Nelson, ACLU of Minnesota, P.O. Box 14720, Minneapolis, MN 55414 (for Plaintiff); 

Andrew T. Jackola and Robert I. Yount, Assistant County Attorneys, Anoka County 
Attorney’s Office, Government Center, 2100 Third Avenue, Seventh Floor, Anoka, 
MN 55303 (for Defendants Anoka County and Anoka County Sheriff James Stuart); 

Alexander James Thillman and Ryan M. Zipf, League of Minnesota Cities, 145 
University Avenue West, St. Paul, MN 55103 (for Defendants Coon Rapids Police 
Officer Nikolas1 Oman and City of Coon Rapids2).                         






1 In the proposed Second Amended Complaint, the spelling of Officer Oman’s first name has been corrected.  (See, 
e.g., Prop. Second Am. Compl. ¶ 19, ECF No. 59-1.)                        
2 The Coon Rapids Police Department was erroneously included in the caption of the initial Complaint, and was 
removed with the filing of the Amended Complaint (ECF No. 40).  Parada v. Anoka Cty., 
332 F. Supp. 3d 1229
, 
1236 n.5 (D. Minn. 2018).                                                 
                       I. INTRODUCTION                                   
    This matter comes before the Court on Plaintiff Myriam Parada’s Motion for Leave 

to Amend Complaint and Modify the Pretrial Scheduling Order (ECF No. 59).  A hearing 
was held on July 25, 2019.  (ECF No. 73.)  Alain M. Baudry and Ian Bratlie appeared on 
behalf of Plaintiff.  Andrew T. Jackola appeared on behalf of Defendants Anoka County 
(“County”)  and  Anoka  County  Sheriff  James  Stuart  (“Sheriff  Stuart”)  (collectively, 
“County Defendants”).  Ryan Zipf appeared on behalf of Defendants Coon Rapids Police 
Officer Nikolas Oman (“Officer Oman”) and City of Coon Rapids (“City”) (collectively, 

“City Defendants”).                                                       
                       II. BACKGROUND                                    
    Plaintiff is a citizen of Mexico and lives in Ramsey, Minnesota.  (Proposed Second 
Am. Compl. ¶ 13.)  Plaintiff entered the United States legally as a child.  (Id.)  On July 25, 
2017, Plaintiff was rear-ended by a Caucasian driver while driving some family members 

home from a birthday party.  (Id. ¶¶ 23, 26.)  Plaintiff called her parents, who came to the 
scene.  (Id. ¶ 27.)  The other driver called the police, and Officer Oman responded.  (Id. 
¶ 28.)  Officer Oman permitted the other driver, who “had 12 convictions for traffic 
violations since 2012 including DWI, speeding and obstructing the legal process,” to leave 
without a citation.  (Id. ¶¶ 30, 31.)                                     

    Officer Oman asked Plaintiff for her driver’s license.  (Id. ¶ 33.)  Plaintiff “did not 
have a Minnesota driver’s license,” and instead “gave him her proof of insurance and a 
Mexican Consular card, commonly referred to as a Matricula Consular card.”  (Id. ¶ 34.)  
“The Matricula Consular card is an official identification card issued by the Mexican 
consulate.”  (Id.)  Plaintiff’s “Matricula Consular card listed her full name, date of birth 
and address in the United States”; included “a recent photo of her”; and contained “security 

features  to  ensure  its  authenticity.”    (Id.  ¶  35.)    Plaintiff  confirmed  that  all  of  the 
information on her Matricula Consular card was accurate.  (Id. ¶ 36.)     
    Plaintiff’s step-father also confirmed the information was accurate and that he was 
the registered owner of the car.  (Id. ¶ 37.)  Plaintiff’s step-father gave Officer Oman “a 
copy of his Minnesota driver’s license.”  (Id.)  “The address on Plaintiff’s Matricula 
Consular card was the same address as Plaintiff’s step-father’s Minnesota driver’s license.”  

(Id. ¶ 38.)  “[T]he VIN number in the Department of Motor Vehicles database of a [car] 
registered . . . . [to Plaintiff’s step-father] matched the VIN number on the proof of 
insurance card in the glove compartment of the car [Plaintiff] was driving.”  (Id.)  Officer 
Oman “ran the name of Plaintiff’s step-father through his database.”  (Id. ¶ 39.) 
    Officer Oman “then spoke with Anoka [C]ounty staff on his personal phone inside 

his car for several minutes.”  (Id. ¶ 40.)  When Officer Oman returned, “he told [Plaintiff] 
that his supervisor told him to bring her in to get her prints,” and “‘I need to make sure who 
you are.’”  (Id. ¶¶ 41-42.)  Plaintiff was arrested and taken to the Anoka County Jail.  (Id. 
¶ 44.)  In a report, Officer Oman “wrote . . . that he ‘transported [Plaintiff] to jail since I 
was also unable to positively identify her.’”  (Id. ¶ 45.)                

    Officer Oman brought Plaintiff to the Anoka County Jail around 7:20 p.m.  (Id. 
¶ 50.)  At the Anoka County Jail, Officer Oman completed an “Authority to Detain” form, 
listing Plaintiff’s name, address, and date of birth as provided at the scene.  (Id. ¶ 51.)  
There was no indication that Officer Oman did not know who Plaintiff was.  (Id.)  The 
“Authority  to  Detain”  form  contains  “a  section  entitled  ‘Reason  for  Detention  for 
Misdemeanors,’” and has boxes to check to indicate that the person is not eligible for 

immediate release.  (Id. ¶ 52.)  Officer Oman did not check any of these boxes “and did not 
make any notations which would suggest that [Plaintiff] was not eligible for immediate 
release.”  (Id.)  Records indicate that Plaintiff “was placed into custody and handed over to 
the Jail only because of a citation for driving without a [Minnesota] driver’s license.”  (Id. 
¶ 51.)                                                                    
    At the Anoka County Jail, Plaintiff was handcuffed, patted down, photographed, 

and placed in a cell.  (Id. ¶¶ 53, 55, 56.)  Records indicate that Plaintiff was cleared and 
free to leave the same day.  (Id. ¶ 59; see id. ¶ 62.)  In an e-mail to Plaintiff’s counsel, 
Lieutenant  Sheila  Larson  with  the  Anoka  County  Sheriff’s  Office  explained  that 
“‘[Plaintiff] was arrested for a Misdemeanor tag/ticket charge, which means she would 
then be processed for release and given a copy of the tag.  There are a few targeted 

misdemeanors that would require us to hold her until seen by a judge, she was not brought 
in for one of those types of Misdemeanors.’”  (Id. ¶ 59.)                 
    Plaintiff was not, however, released on July 25.  (See id. ¶ 64.)  At approximately 
11:00 p.m., Plaintiff was brought to an unidentified County staff member, the unknown 
County Defendant, “who questioned her for a few minutes and then brought her back to 

her cell.”  (Id. ¶ 67.)  About half an hour later, Plaintiff was again brought to see the 
unknown County Defendant, who “handed [her] a phone and instructed [her] to talk to the 
person on the other end.”  (Id. ¶¶ 68, 69.)                               
    On the other end of the line were agents with United States Immigration and 
Customs Enforcement (“ICE”).  (Id. ¶ 70.)  ICE asked Plaintiff if she was a United States 
citizen and how she arrived in the United States.  (Id.)  Plaintiff asked the unknown County 

Defendant if she needed a lawyer, and was told to ask ICE.  (Id. ¶¶ 71, 72.)  ICE told 
Plaintiff “that ‘it goes faster without a lawyer.’”  (Id. ¶ 73.)  Plaintiff then told ICE “how 
she entered the United States.”  (Id. ¶ 74.)  After Plaintiff was done speaking with ICE, the 
unknown  County  Defendant  took  her  back  to  her  cell.    (Id.  ¶  75.)    Plaintiff  was 
fingerprinted approximately an hour later.  (Id.)                         
    In the early morning hours of July 26, ICE sent an I-200 Warrant for Arrest of an 

Alien (“ICE Warrant”) and I-247 ICE Detainer (“ICE Detainer”) to the Anoka County Jail.  
(Id. ¶¶ 76, 77, 93.)  The ICE Warrant was unsigned and not served on Plaintiff.  (Id. ¶¶ 76, 
94, 104.)  The ICE Detainer was stamped “Draft Not Complete” on each page and also not 
served on Plaintiff.  (Id. ¶¶ 77, 104.)  Around 2:00 a.m., Plaintiff was brought out of her 
cell, given a citation for not having a Minnesota driver’s license, and handed over to two 

ICE agents.  (Id. ¶¶ 81, 82.)  Plaintiff was handcuffed, shackled, and taken to the Sherburne 
County Jail.  (Id. ¶ 84.)  About an hour later, Plaintiff’s family was informed that she was 
in ICE custody.  (Id. ¶ 85.)  Plaintiff is currently in removal proceedings.  (Id. ¶ 87.) 
    Among others, Plaintiff brings claims against Defendants pursuant to 
42 U.S.C. § 1983
 for violations of her constitutional rights and false imprisonment under Minnesota 

common law.                                                               
                     III. MOTION TO AMEND                                

    Plaintiff requests leave to amend the Amended Complaint to seek punitive damages 
in connection with her federal § 1983 claims and common-law false-imprisonment claim.  
Plaintiff also seeks leave to add a § 1983 claim for violation of her equal-protection rights 
under the Fourteenth Amendment against the County Defendants.             
    A. Legal Standard                                                    
    With the exception of amendments as a matter of course, the Federal Rules of Civil 
Procedure permit a party to “amend its pleadings only with the opposing party’s written 

consent or the court’s leave.”  Fed. R. Civ. P. 15(a)(2).  The Rules further provide that 
leave should be freely given “when justice so requires.”  Id.  There is, however, “no 
absolute right to amend” and a finding of undue delay, bad faith, dilatory motive, undue 
prejudice to the non-moving party, or futility may be grounds to deny a motion to amend.  
Doe v. Cassel, 
403 F.3d 986, 990-91
 (8th Cir. 2005).  “Fundamentally, ‘the grant or denial 

of an opportunity to amend is within the discretion of the District Court.’”  Ash v. Anderson 
Merchandisers, LLC, 
799 F.3d 957, 963
 (8th Cir. 2015) (quoting Foman v. Davis, 
371 U.S. 178, 182
 (1962)).                                                         
    B. Equal-Protection Claim Against the County Defendants              
    The Court begins with Plaintiff’s proposed § 1983 claim for violation of her equal-

protection rights under the Fourteenth Amendment against the County Defendants. 
         1.  Good Cause                                                  
    With the exception of motions to seek punitive damages, the deadline for motions 
to amend the pleadings was December 15, 2018.  (ECF No. 56 at 3.)  As Plaintiff’s motion 
was filed after that deadline, Plaintiff must show good cause for modification of the 
deadline.  Sherman v. Winco Fireworks, Inc., 
532 F.3d 709, 716-17
 (8th Cir. 2008).  “The 

primary measure of good cause is the  movant’s diligence in attempting  to  meet the 
scheduling order’s requirements.”  Harris v. FedEx Nat’l LTL, Inc., 
760 F.3d 780, 786
 (8th 
Cir. 2014) (quotation omitted); see also Sherman, 
532 F.3d at 716-17
.  “The ‘good cause’ 
standard is an exacting one, for it demands a demonstration that the existing schedule 
cannot reasonably be met despite the diligence of the party seeking the extension.”  Khoday 
v. Symantec Corp., No. 11-cv-180 (JRT/TNL), 
2013 WL 12141434
, at *2 (D. Minn. May 

15, 2013) (quotation omitted).                                            
    Plaintiff asserts that she discovered the basis for her proposed equal-protection 
claim against the County Defendants during a 30(b)(6) deposition of the County, which 
took place on June 18, 2019.  The County appeared through Commander David Pacholl.3  
During the deposition, Commander Pacholl testified that the Anoka County Jail notifies 

ICE as part of its booking procedure when an individual identifies him or herself as having 
been born outside of the United States, states that he or she is not a United States citizen or 
is a foreign national, or provides “data” from another country.  (Dep. of David Pacholl 
160:12-169:1, Ex. 4 to Aff. of Amanda Cefalu, ECF No. 60-4.)  Commander Pacholl 
testified that there is an automated, law-enforcement electronic communication program 

through which ICE is notified, and the Anoka County Jail may also follow up with ICE via 
telephone if a response is not received in connection with the automated notification.  


3 At the hearing, counsel for the County Defendants stated that Commander Pacholl is the highest ranking official 
for the Anoka County Jail.                                                
(Pacholl Dep. 163:1-165:13.)  It is this automatic notification to ICE that forms the basis 
of Plaintiff’s proposed equal-protection claim.  See infra Section III.B.2.b.   

    The County Defendants respond that parties have been engaged in discovery for 
nearly a year, and Plaintiff could have taken this deposition sooner.  They additionally 
respond that, with little time left for fact discovery, it “is too late” for Plaintiff “to inject a 
new theory of liability” into this case.  (County Opp’n at 14, ECF No. 68.)  At the hearing, 
the Court inquired as to whether the existing pretrial schedule would need to be amended 
should Plaintiff be permitted to add this claim.  Plaintiff and the County Defendants each 

confirmed that no adjustments would be needed.                            
    The  Court  finds  that  Plaintiff  has  been  diligent  in  attempting  to  meet  the 
requirements of the scheduling order.  Plaintiff reasonably pursued information regarding 
the County Defendants’ policies and communications with ICE through other discovery 
methods during the fact discovery period, and learned of the automatic notification process 

during a 30(b)(6) deposition taken more than two months before the close of fact discovery.  
Once she became aware of the automatic notification process, Plaintiff promptly moved to 
amend.  Further, having found that Plaintiff was diligent in meeting the requirements of 
the scheduling order, it is also relevant the County Defendants have not articulated any 
specific prejudice resulting from the timing of the amendment.  As stated above, Plaintiff 

and the County Defendants agree that, if granted, the proposed amendment would not affect 
any of the existing deadlines.  Accordingly, Plaintiff has shown good cause to seek leave 
to amend past the December 15, 2018 deadline.                             
         2.  Futility of the Amendment                                   

    The  County  Defendants  oppose  Plaintiff’s proposed  equal-protection  claim  on 
grounds that it is futile.                                                
              a.  Legal Standard                                         
    “Futility  is  a  well-recognized  basis  for  denying  a  proposed  amendment.”  
ecoNugenics, Inc. v. Bioenergy Life Sci., Inc., 
355 F. Supp. 3d 785, 793
 (D. Minn. 2019) 
(citing Foman, 
371 U.S. at 182
); see, e.g., Lansing v. Wells Fargo Bank, N.A., 
894 F.3d 967, 973-74
 (8th Cir. 2018) (“[A] district court properly denies leave when a proposed 

amendment would be futile.”); Munro v. Lucy Activewear, Inc., 
899 F.3d 585, 589
 (8th Cir. 
2018)  (“However,  futility  is  a  valid  basis  for  denying  leave  to  amend.”  (quotation 
omitted)).  “An amendment is futile if the amended claim could not withstand a motion to 
dismiss under Rule 12(b)(6).”  Hillesheim v. Myron’s Cards & Gifts, Inc., 
897 F.3d 953, 955
 (8th Cir. 2018) (quotation omitted); accord Cornelia I. Crowell GST Tr. v. Possis 

Med., Inc., 
519 F.3d 778, 782
 (8th Cir. 2008) (“[W]hen the court denies leave on the basis 
of futility, it means the district court has reached the legal conclusion that the amended 
complaint could not withstand a motion to dismiss under Rule 12(b)(6) of the Federal Rules 
of Civil Procedure.”).                                                    
    “To withstand a Rule 12(b)(6) motion, a complaint must contain sufficient factual 

allegations to ‘state a claim to relief that is plausible on its face.’”  Smithrud v. City of St. 
Paul, 
746 F.3d 391, 397
 (8th Cir. 2014) (quoting Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 547
 (2007)).  “A claim has facial plausibility when the plaintiff pleads factual content that 
allows the court to draw the reasonable inference that the defendant is liable for the 
misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (citing Twombly, 
550 U.S. at 556
).  “[A]lthough a complaint need not contain ‘detailed factual allegations,’ it 

must contain facts with enough specificity ‘to raise a right to relief above the speculative 
level.’”  U.S. ex rel. Raynor v. Nat’l Rural Utils. Coop. Fin., Corp., 
690 F.3d 951, 955
 (8th 
Cir. 2012) (quoting Twombly, 
550 U.S. at 555
).  “A pleading that offers ‘labels and 
conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’”  
Iqbal, 
556 U.S. at 678
 (quoting Twombly, 
550 U.S. at 555
).  Similarly, “[t]hreadbare 
recitals of the elements of a cause of action, supported by mere conclusory statements, do 

not suffice.”  
Id.
  “In deciding a motion to dismiss under Rule 12(b)(6), a court assumes all 
facts in the complaint to be true and construes all reasonable inferences most favorably to 
the complainant.”  Raynor, 
690 F.3d at 955
.                               
              b.  Allegations                                            

    Plaintiff’s proposed equal-protection claim is based on the County Defendants 
automatically notifying ICE whenever a person born outside of the United States is brought 
to the Anoka County Jail and selectively detaining foreign-born persons who are otherwise 
eligible for release.4  The district court previously articulated the elements of an equal-


4 Plaintiff inconsistently refers to the class of individuals she alleges were subject to differing treatment.  
Throughout Plaintiff’s pleadings and in her memorandum in support of the instant motion, Plaintiff appears to refer 
to the same class of individuals interchangeably as “foreign-born” persons and “noncitizens.”  Such terms are not 
interchangeable.  While an individual may fall into both categories, an individual may also be born outside of the 
United States and still be a citizen of the United States.  More often than not, Plaintiff uses the term “noncitizens.”  
(Compare, e.g., Proposed Second Am. Compl. ¶¶ 130, 192, 195, A-C (foreign-born) with ¶¶ 65, 66, 160-162, 165 
(noncitizen) with ¶¶ 6, 119 (use of both); Pl.’s Mem. in Supp. passim (use of noncitizen, not foreign-born).)  At the 
hearing, the Court sought clarification as to the class of individuals to which Plaintiff is referring.  Plaintiff’s counsel 
stated that the class of individuals at issue were people born outside of the United States, i.e., foreign-born, not 
noncitizens.  Based on the representation of Plaintiff’s counsel, the Court uses the term “foreign-born.”  See infra 
n.7.                                                                      
protection claim based on selective enforcement:                          
         Immigrants−even if unlawfully present−are protected by the      
         Equal Protection Clause.  Plyler v. Doe, 
457 U.S. 202, 210
, 
102 S. Ct. 2382
,  
72 L.Ed.2d 786
  (1982).    “[T]he  Constitution 
         prohibits  selective  enforcement  of  the  law  based  on      
         considerations such as race.”  Whren v. United States, 
517 U.S. 806, 813
, 
116 S. Ct. 1769
, 
135 L.Ed.2d 89
 (1996).  A selective- 
         enforcement claim does not require proof that the plaintiff was 
         arrested without probable cause or reasonable suspicion to      
         believe  that  the  plaintiff  committed  a  criminal  offense.  
         Johnson v. Crooks, 
326 F.3d 995, 999-1000
 (8th Cir. 2003).      
         Rather, the plaintiff must prove that the officer exercised his or 
         her discretion to enforce the laws on account of the plaintiff's 
         race, nationality, or other characteristics.  See 
id. at 1000
.  
         “When the claim is selective enforcement of the traffic laws or 
         a racially-motived arrest, the plaintiff must normally prove that 
         similarly situated individuals were not stopped or arrested in  
         order to show the requisite discriminatory effect and purpose.”  
         
Id.
                                                             

Parada, 
332 F. Supp. 3d at 1244
.                                          
    Plaintiff alleges that the County Defendants “acted pursuant to an unwritten policy, 
custom, or pattern or practice to engage in discrimination on the basis of national origin or 
ethnicity by automatically contacting ICE any time a [foreign-born person] is brought to 
the Anoka County [Jail].”  (Proposed Second Am. Compl. ¶ 160; see Proposed Second 
Am. Compl. ¶ 65.)  Plaintiff further alleges that the County Defendants detain foreign-born 
persons who are otherwise eligible for release longer than similarly-situated individuals, 
namely, until ICE arrives, thereby discriminating against foreign-born persons based on 
their national origin and/or ethnicity.  (Proposed Second Am. Compl. ¶¶ 65, 161-62, 165.)  
Plaintiff also alleges that the County Defendants “have intentionally targeted Hispanic 
individuals who are brought to the Anoka County [J]ail to be subject to unlawful detention 
and turnover to ICE.”  (Proposed Second Am. Compl. ¶ 164.)                
    The County Defendants complain that Plaintiff has not articulated how this “class” 

of persons allegedly subject to different treatment “has been or continues to suffer a harm 
associated with their distinct treatment,” arguing that “the claim is suspect because who 
else, besides non-citizens, would be subject to the jurisdiction of ICE for purposes of 
checking immigration status.”  (County Opp’n at 15.)  Plaintiff’s proposed equal-protection 
claim is not, however, solely grounded in the County Defendants’ communications with 
ICE.  Plaintiff has alleged that foreign-born persons who are otherwise eligible for release 

are detained longer than other individuals otherwise eligible for release based on their race, 
nationality, and perceived immigration status.  The harm alleged is the prolonged detention 
of a foreign-born person who is otherwise eligible for release.  The remainder of the County 
Defendants’ arguments go to the merits of Plaintiff’s proposed equal-protection claim and 
not to whether Plaintiff has stated a claim.                              

    Here, Plaintiff has plausibly alleged that (1) she was eligible for release but detained 
on account of her race, nationality, and perceived immigration status; (2) the County 
Defendants acted pursuant to an unwritten policy, custom, pattern or practice to engage in 
racial profiling, and (3) other similarly situated individuals eligible for release were not 
subject to such detention.  See Parada, 
332 F. Supp. 3d at 1245
.  Plaintiff’s proposed equal-

protection claim against the County Defendants is not futile, and therefore the Court will 
grant Plaintiff’s motion with respect to this claim.                      
    C. Punitive Damages                                                  

    Plaintiff also seeks leave to include a request for punitive damages in connection 
with her federal § 1983 claims and common-law, false-imprisonment claim.  At the 
hearing, Plaintiff clarified that she is only seeking punitive damages against Officer Oman 
and  Sheriff  Stuart  individually,  not  in  their  official  capacities,  and  not  against  the 
governmental entities.  Plaintiff’s motion to add punitive damages is timely. 
         1.  § 1983 Claims                                               

    A request to add punitive damages in connection with a claim brought pursuant to 
42 U.S.C. § 1983
 is governed by Rule 15 of the Federal Rules of Civil Procedure.  Le-Vert-
Woitalla v. Carver Cty., No. 11-cv-238 (JRT/JJK), 
2011 WL 13233268
, at *5 (D. Minn. 
July 7, 2011).  While the City Defendants do not concede that Plaintiff is entitled to recover 
punitive damages in connection with her § 1983 claims against Officer Oman in his 
individual capacity, they do not object to Plaintiff’s request to seek such damages.  The 

County Defendants object to the inclusion of a request for punitive damages against Sheriff 
Stuart on grounds that he was not personally involved in the events in question and is not 
liable on Plaintiff’s claims.                                             
    “Punitive damages may be awarded under 
42 U.S.C. § 1983
 ‘when the defendant’s 
conduct is shown to be motivated by evil motive or intent, or when it involves reckless or 

callous indifference to the federally protected rights of others.’”  Schaub v. VonWald, 
638 F.3d 905, 922
 (8th Cir. 2011) (quoting Smith v. Wade, 
461 U.S. 30, 56
 (1983)); accord 
Washington  v.  Denney,  
900 F.3d 549, 563-64
  (8th  Cir.  2018).    “Proving  reckless 
indifference requires evidence that the defendant acted in the face of a perceived risk that 
his or her actions would violate federal law.”  McAdoo v. Martin, 
899 F.3d 521, 527
 (8th 
Cir. 2018) (quotation omitted).  “Punitive damages punish a defendant for outrageous, 

intentional, or malicious conduct, and deter similar extreme conduct in the future.”  Schaub, 
638 F.3d at 922-23
 (footnote omitted).  “It is a question of fact whether a defendant’s 
conduct was motivated by an evil motive or involves reckless indifference to the federally 
protected rights of others.”  
Id. at 923
.  Thus, “[w]hile an award of compensatory damages 
is mandatory upon a finding of liability, punitive damages are awarded or rejected in a 
particular case at the discretion of the factfinder once sufficiently serious misconduct by 

the defendant is shown.”  Washington, 
900 F.3d at 563
 (quotation omitted).  “The factfinder 
focuses on the defendant’s intent in determining whether to award punitive damages and 
whether the defendant’s conduct is of the sort that calls for deterrence and punishment over 
and above that provided by compensatory awards.”  
Id. at 563-64
 (quotation omitted). 
    The County Defendants are essentially asking this Court to render a dispositive 

ruling on the merits of Plaintiff’s claims.  Yet, the County Defendants did not challenge 
the sufficiency of Plaintiff’s existing § 1983 claims in a motion to dismiss and, as stated 
above, the Court has concluded that Plaintiff’s proposed equal-protection allegations state 
a claim.  Punitive damages are authorized in connection with § 1983 claims.  See, e.g., 
Schaub, 
638 F.3d at 922
; Le-Vert-Woitalla, 
2011 WL 13233268
, at *5.  The County 

Defendants can argue at a more procedurally appropriate juncture the merits of their 
position, including fundamental questions of liability and whether the evidence supports a 
finding of evil motive, intent, or reckless or callous indifference to the federally protected 
rights of others.                                                         
    Therefore, Plaintiff’s motion is granted with respect to her § 1983 claims, and she 
may amend the Amended Complaint to seek punitive damages against Officer Oman and 

Sherriff  Stuart  in  their  individual  capacities  in  connection  with  her  §  1983  claims.  
Consistent with this ruling, the Court will permit the inclusion of the proposed additional 
factual allegations.                                                      
         2.  False-Imprisonment Claim                                    

    Plaintiff also seeks leave to pursue punitive damages against Officer Oman and 
Sheriff Stuart in connection with her common-law false imprisonment claim.  Plaintiff has 
presented her arguments under 
Minn. Stat. §§ 549.191
 and 549.20.  (Pl.’s Mem. in Supp. 
at 12-14, ECF No. 77; see Pl.’s Mem. in Supp. at 19-20.)  Accordingly, the Court proceeds 
thereunder.  Cf. Shank v. Carleton College, No. 16-cv-1154 (PJS/HB), 
2018 WL 4961472
, 
at *4 (D. Minn. Oct. 15, 2018).                                           
              a.  Legal Standard                                         

    Under Minnesota law, a party must move for leave to amend the pleadings to include 
punitive damages.  
Minn. Stat. § 549.191
; Olson v. Snap Prods., Inc., 
29 F. Supp. 2d 1027, 1034
 (D. Minn. 1998).  “The motion must allege the applicable legal basis under [§] 549.20 
or other law for awarding punitive damages in the action and must be accompanied by one 
or more affidavits showing the factual basis for the claim.”  
Minn. Stat. § 549.191.5
  “[I]f 


5 At the hearing, Plaintiff presented a collection of 14 exhibits to the Court in support of her motion (“Hearing 
Exhibits”).  Some of the Hearing Exhibits were duplicative of exhibits attached to the affidavit of Amanda Cefalu 
filed in support of Plaintiff’s motion.  These duplicative exhibits include: Plaintiff’s Matricula Consular card (Ex. 1 
to Cefalu Aff., ECF No. 60-1; Hearing Ex. 1); the preliminary expert report of Roy Bedard (Ex. 2 to Cefalu Aff., 
ECF No. 60-2; Hearing Ex. 9); the Authority to Detain Form (Ex. 3 to Cefalu Aff., ECF No. 60-3 at 2; Hearing Ex. 
8); Officer Oman’s incident report (Ex. 3 to Cefalu Aff., ECF No. 60-3 at 3; Hearing Ex. 7); excerpts from 
Commander Pacholl’s 30(b)(6) deposition (Ex. 4 to Cefalu Aff., ECF No. 60-4 at 2-15; Hearing Ex. 11); e-mail 
correspondence on April 17, 2017, between Commander Pacholl and Bryan R. Lindberg (Ex. 4 to Cefalu Aff., ECF 
the court finds prima facie evidence in support of the motion, the court shall grant the 
moving party permission to amend the pleadings.”  
Id.
                     

    Punitive damages are permitted “only upon clear and convincing evidence that the 
acts of the defendant show deliberate disregard for the rights or safety of others.”  
Minn. Stat. § 549.20
, subd. 1(a).                                               
         A defendant has acted with deliberate disregard for the rights  
         or safety of others if the defendant has knowledge of facts or  
         intentionally disregards facts that create a high probability of 
         injury to the rights or safety of others and:                   

              (1)  deliberately  proceeds  to  act  in  conscious  or    
         intentional disregard of the high degree of probability of injury 
         to the rights or safety of others; or                           

              (2) deliberately proceeds to act with indifference to the  
         high probability of injury to the rights or safety of others.   

Id.,
 subd. 1(b).  “Clear and convincing evidence is more than a preponderance of the 

No. 60-4 at 19-20; Hearing Ex. 12); and a January 5, 2018 e-mail from Lieutenant Larson to Plaintiff’s counsel (Ex. 
4 to Cefalu Aff., ECF No. 60-4 at 21; Hearing Ex. 10).  Hearing Exhibits 2 and 3 were not filed in connection with 
the instant motion, but appear to have been previously filed as part of Plaintiff’s opposition to the City Defendants’ 
motion to dismiss.  But see Parada, 
332 F. Supp. 3d at 1238
 (declining to consider evidence submitted outside of the 
pleadings on motion under Fed. R. Civ. P. 12(b)(6)).  Hearing Exhibit 2 is the insurance card of Plaintiff’s 
stepfather.  (ECF No. 22-2.)  Hearing Exhibit 3 is the Minnesota driver’s license of Plaintiff’s stepfather.  (ECF No. 
26.)  Hearing Exhibit 6 is a copy of a PATROL (“Police Accredited TRaining OnLine” [sic]) course summary for 
misdemeanor arrests, which was appears to be training that was provided to Officer Oman.  A single page 
(CR000015) of this three-page (CR000013-15) summary was attached to Plaintiff’s preliminary expert report.  (Ex. 
2 to Cefalu Aff., ECF No. 60-2 at 6.)                                     
    Hearing Exhibits 4, 5, 13, and 14 were presented for the first time at the hearing.  At the hearing, Plaintiff’s 
counsel explained that Hearing Exhibit 4 is the information returned when Officer Oman ran the car Plaintiff was 
driving.  Hearing Exhibit 5 was described as an example of information returned if someone were to perform an 
Internet search for “Matricula Consular,” which Plaintiff’s expert opined “[a] curious officer could . . .” do.  (Ex. 60-
2 at 3.)  Hearing Exhibit 13 is a copy of the district judge’s ruling on the City Defendants’ motion to dismiss.  
Hearing Exhibit 14 contains excerpts from the July 24, 2019 depositions of Lieutenant Larson and Wayne Heath.  
These depositions were taken the day before the hearing and the transcript excerpts provided to the Court are 
uncertified, rough drafts.                                                
    At the hearing, the Court expressed frustration with such after-the-fact submissions, presented on the day of 
the hearing, after briefing had been complete.  The Court also expressed reservations about the use of uncertified, 
unofficial transcripts, and Plaintiff agreed to proceed without them.  Plaintiff shall file Hearing Exhibits 4, 5, and 6 
within 7 days from the date of this Order.                                
evidence but less than proof beyond a reasonable doubt.”  In re Levaquin Prods. Liab. 
Litig., MDL No. 08-1943 (JRT), No. 08-cv-5743 (JRT), 
2010 WL 7852346
, at *5 (D. 

Minn. Nov. 9, 2010) (quotation omitted); accord Olson, 
29 F. Supp. 2d at 1036
.  Olson 
instructs that this standard is satisfied when “the evidence is sufficient to permit the Jury 
to conclude that it is ‘highly probable’ that the defendant acted with deliberate disregard to 
the rights or safety of others.”  
29 F. Supp. 2d at 1036
 (quotation omitted). 
    At this stage, “[a] plaintiff need not demonstrate an entitlement to punitive damages 
per se, but only an entitlement to allege such damages.”  Berczyk v. Emerson Tool Co., 
291 F. Supp. 2d 1004, 1008
 (D. Minn. 2003) (footnote omitted); accord In re Levaquin Prods. 
Liab. Litig., 
2010 WL 7852346
, at *6.  Under Minnesota law, “‘prima facie’ does not refer 
to  a  quantum  of  evidence”;  rather,  “prima  facie  evidence  is  that  evidence  which, if 
unrebutted, would support a judgment in that party’s favor.”  Olson, 
29 F. Supp. 2d at 1034
 
(quotations omitted).  The Court does not make any credibility determinations or consider 

challenges to the evidence when determining whether a prima facie showing has been 
made.  Freeland v. Fin. Recovery Servs., Inc., 
790 F. Supp. 2d 991, 994
 (D. Minn. 2011).  
Nevertheless, “when presented with a [m]otion for leave to assert a punitive damage claim, 
the function of the Court is to do more than ‘rubber stamp’ the allegations in the [m]otion 
papers.”  Ulrich v. City of Crosby, 
848 F. Supp. 861, 868
 (D. Minn. 1994).  “[T]he Court 

must carefully scrutinize the evidence presented by the moving party to make sure that it 
amounts to a prima facie showing that the substantive requirements for punitive damages 
have been met.”  Healey v. I-Flow, LLC, 
853 F. Supp. 2d 868, 873
 (D. Minn. 2012); see 
Ulrich, 
848 F. Supp. at 868-69
.                                           
              b.  Elements of False Imprisonment                         
    “The tort of false imprisonment or false arrest protects the personal interest in 

freedom from restraint of movement.”  Strei v. Blaine, 
996 F. Supp. 2d 763, 789
 (D. Minn. 
2014) (quotation omitted); see also Riehm v. Engelking, 
538 F.3d 952, 969
 (8th Cir. 2008) 
(“According  to  Minnesota  common  law,  [a]n  individual  may  not,  without  legal 
justification, be confined against his or her will.” (quotation omitted)).  “An arrest made 
without proper legal  authority is a false arrest, and  any subsequent restraint is false 
imprisonment.”  Binion v. City of St. Paul, 
788 F. Supp. 2d 935, 949
 (D. Minn. 2011) 

(quotation  omitted);  accord  Strei,  
996 F. Supp. 2d at 789
.    “To  establish  a  false-
imprisonment claim against law enforcement, the plaintiff must prove that defendants 
performed an arrest and the arrest was unlawful.”  Parada, 
332 F. Supp. 3d at 1246
. 
                  i.  Officer Oman                                       
    Plaintiff argues that “there is evidence from which it may be inferred that Officer 

Oman was never in doubt about [her] true identity, and made no attempt to consider relying 
on the available corroboration,” and that a reasonable jury could conclude that Officer 
Oman “intentionally imprisoned [her] on false pretenses for the purpose of getting ICE 
involved.”  (Pl.’s Mem. in Supp. at 20-21.)                               
    Plaintiff has presented evidence that Officer Oman had before him several pieces of 

information corroborating her identity.  These included her Matricula Consular card, the 
insurance card, the driver’s license of her stepfather, and the results of the search Officer 
Oman ran on the car she was driving.  Plaintiff has also presented evidence in the form of 
a preliminary expert report that, along with her self-identification and her stepfather’s 
verbal identification, a reasonable officer would have accepted the information provided 
by Plaintiff and concluded that she was who she said she was and resided at the address 

shown.                                                                    
    As to Plaintiff’s allegation that Officer Oman was “motivated by anti-immigrant 
animus,” Plaintiff states that she “discovered . . . [that Officer] Oman issued at least six 
citations for no Minnesota driver’s license in the last year without arresting the individuals 
and taking them into custody,” and “liked” two individuals and a news organization on 
social media, which “have publicly professed strongly anti-immigrant views. ”  (Pl.’s Mem. 

in Supp. at 10-11.)  Plaintiff further states,                            
         upon  information  and  belief,  that based  upon  his  years  of 
         working for the [City’s] Police Department, and his numerous    
         interactions  with  the  Anoka  County  Jail  and  Sheriff’s    
         department, Officer Oman was aware of [the County’s] policy     
         or  practice  of  automatically  contacting  ICE  when  non-US  
         citizens were brought to the Anoka County [J]ail and thus that  
         [she] would come to the attention of ICE by virtue of his       
         decision to detain her.                                         

(Pl.’s Mem. in Supp. at 17.)  Yet, Plaintiff has not presented evidence of situations where 
Officer Oman previously issued citations to, rather than arresting, an individual without a 
Minnesota driver’s license.  Plaintiff has not presented evidence that Officer Oman was 
aware that the County would contact ICE as part of its booking process.  Nor has Plaintiff 
presented evidence of Officer Oman’s tenure with the City’s police department or his prior 
interactions with the Anoka County Jail and County Defendants.            
    With respect to social media, Plaintiff has not presented evidence from which a jury 
could reasonably infer that Officer Oman was motivated by—or even has—anti-immigrant 
views.  Plaintiff has attached a print-out from Officer Oman’s Facebook page, showing 
that Officer Oman has “liked” more than 160 social media sites, including restaurants, 

automobile manufactures, public figures, law enforcement agencies, news organizations, 
and sporting goods retailers, among others.  (Ex. 5 to Cefalu Aff., ECF No. 60-5.)  Of these, 
Plaintiff singles out three and states these two individuals and a news organization have 
expressed anti-immigrant views.  Other than excerpting a quote from a news article without 
including the article itself, Plaintiff has not presented evidence regarding the purported 
anti-immigrant views of one of these individuals.  Plaintiff has not presented evidence 

regarding the news organization other than to state that it aired a program on which the 
second individual appeared.  As for the second individual, Plaintiff has included an article 
which quotes statements the second individual made during the program aired by the news 
organization.  But, even assuming these two individuals and the news organization at one 
point or another expressed anti-immigrant views, there is no evidence in the record that 

Officer Oman shares or endorses these views.  There is no evidence in the record as to why 
Officer  Oman  “liked”  the  social  media  sites  of  these  two  individuals  and  the  news 
organization.  Plaintiff is asking this Court to engage in pure speculation as to Officer 
Oman’s interest in these three social media sites.6                       
    Plaintiff also purports to rely the district court’s ruling on the City Defendants’ 

motion to dismiss as evidence that her arrest was pretextual.  The district court, however, 
was commenting on the sufficiency of Plaintiff’s allegations and whether she had stated a 


6 To say nothing of the complicated potential First Amendment issues that may arise in connection with presumed 
imputations of invidiousness based on what news or social media one follows. 
claim, not evidence.  In fact, the district court acknowledged that evidence had been 
submitted outside of the pleadings in connection with the motion to dismiss, but expressly 

“exclude[d] the submitted evidence and . . . consider[ed] the motion under Rule 12(b)(6).”  
Parada, 
332 F. Supp. 3d at 1238
.  Under these circumstances, the district court’s ruling 
does not supply a factual basis to support Plaintiff’s contention that Officer Oman acted 
with deliberate disregard for her rights.                                 
    Rather than the pretextual, anti-immigrant motive Plaintiff asks the Court to infer, 
the unrebutted evidence could as easily suggest that Officer Oman was in fact unfamiliar 

with a Matricula Consular card, and brought Plaintiff in because he was not able to verify 
her identification.  See Romano v. ReliaStar Life Ins. Co., No. 12-cv-137 (SRN/JJK), 
2012 WL 5907397
, at *6 (D. Minn. Nov. 26, 2012).  While Plaintiff’s expert has opined that a 
reasonable officer would have relied on the Matricula Consular card, Plaintiff has also 
presented evidence in the form of a memorandum from the City’s chief of police, stating 

that he had “never heard of a Matricula Consular card” prior to this incident and was not 
aware “of any State Law or Court Order instructing law enforcement to accept this card as 
proof of identity.”  (Ex. 7 to Cefalu Aff., ECF No. 60-7 at 2.)  Moreover, as Plaintiff herself 
points out, Officer Oman did not check any of the exceptions to eligibility for immediate 
release “and did not make any notations which would suggest that [she] was not eligible 

for immediate release” when completing the Authority to Detain form at the Anoka County 
Jail.  (Pl.’s Mem. in Supp. at 7.)  The possibility of an innocent explanation for Officer 
Oman’s decision to arrest Plaintiff undermines her argument that she has presented prima 
facie evidence that Officer Oman acted with deliberate disregard for her rights.  See 
Romano, 
2012 WL 5907397
, at *6; see also Smith v. Morales, No. A07-2377, 
2008 WL 4909630
, at *4-5 (Minn. Ct. App. Nov. 18, 2008).                          

    At best, Plaintiff has presented evidence that Officer Oman may have been negligent 
in not relying on her Matricula Consular card and other corroborating information.  But 
negligence, even gross negligence, is not enough to rise to the level of deliberate disregard 
for the rights of another.  See Freeland, 
790 F. Supp. 2d at 994-95
; Berczyk, 
291 F. Supp. 2d at 1008
; Olson, 
29 F. Supp. 2d at 1035
.  And, the fact that Plaintiff’s arrest may have 
been improper is not by itself sufficient to sustain a request for punitive damages.  Ward v. 

Nat’l  Car  Rental  Sys.,  
290 N.W.2d 441, 443
  (Minn.  1980);  see  Porter  v.  City  of 
Minneapolis, No. 13-cv-2499 (MJD/FLN), 
2014 WL 12607719
, at *4 (D. Minn. Sept. 29, 
2014). Section 549.191 “requires more than the presentation of evidence that is simply 
consistent with a plaintiff’s claim.  Th[is] gatekeeping statute requires prima facie evidence 
that clearly and convincingly suggests a deliberate disregard for the plaintiff’s rights.”  

Romano,  
2012 WL 5907397
,  at  *6.    While  “[a]  plaintiff  may  appropriately  rely  on 
inferences that can be drawn from other evidence in the record . . . if that evidence clearly 
and convincingly suggests an inference of deliberate disregard of the [plaintiff’s] rights,” 
the Court cannot draw such an inference with respect to Officer Oman from the evidence 
proffered by Plaintiff.  
Id. at *7
.                                       

    Based on the foregoing, the Court concludes that Plaintiff has not presented prima 
facie evidence that Officer Oman acted with deliberate disregard of her rights when he 
arrested her.  Therefore, Plaintiff’s motion is denied with respect to her request to seek 
punitive damages in connection with her false-imprisonment claim against Officer Oman. 
                 ii.  Sheriff Stuart                                     
    Plaintiff argues that Sherriff Stuart “intentionally prolong[ed] her detention,” and 

“treated [her] as an immigration detainee from the outset.”  (Pl.’s Mem. in Supp. at 20, 21.) 
    It is worth emphasizing that Plaintiff is requesting leave to pursue punitive damages 
against Sheriff Stuart in his individual capacity.  As the County Defendants point out, 
Plaintiff has not presented evidence “that Sheriff Stuart was at the jail on the night of her 
arrest or knew anything about her detention as it was happening.”  (County Opp’n at 12.)  
There is no evidence in the record that Sheriff Stuart was personally involved in Plaintiff’s 

detention at the Anoka County Jail.                                       
    Plaintiff points to evidence that Sheriff Stuart “oversees the jail,” (Pacholl Dep. 
37:11), and the County’s 30(b)(6) testimony that the Anoka County Jail relies on the 
arresting officer and the court system as to whether an arrest was lawful.  Plaintiff contends 
that “[t]his admission demonstrates that the Anoka County Sheriff accepted [her] into the 

Jail facility with no regard for whether or not Officer Oman had probable cause to arrest 
her.”  (Pl.’s Mem. in Supp. at 18.)  Plaintiff also relies on Lieutenant Larson’s January 5, 
2018  e-mail,  in  which  Lieutenant  Larson  stated  that  Plaintiff  “was  arrested  for  a 
Misdemeanor tag/ticket charge, which means she would not be held in custody once she is 
booked, she would then be processed for release and given a copy of the tag,” and that 

Plaintiff was not brought in for a type of misdemeanor that would require her to be held.  
(ECF No. 60-4 at 21.)  Plaintiff argues that this is an “admi[ssion] that [she] never should 
have been detained.”  (Pl.’s Mem. in Supp. at 8.)                         
    Again,  even  assuming  for  purposes  of  this  motion  that  Plaintiff’s  arrest  and 
detention were improper, this is not sufficient to sustain a request for punitive damages in 
connection with her false-imprisonment claim.  Ward, 
290 N.W.2d at 443
; see Porter, 
2014 WL 12607719
, at *4; see also Romano, 
2012 WL 5907397
, at *6.  And, again, Plaintiff 
has not presented evidence that Sheriff Stuart was personally involved in her detention.  
Nor has Plaintiff presented evidence showing—or even argued—that punitive damages 
should be allowed under some sort of master-and-principal theory as to any acts by other 
individuals at the Anoka County Jail.  See 
Minn. Stat. § 549.20
, subd. 2 (describing 
situations in which punitive damages may be “awarded against a master or principal 

because of an act done by an agent”).                                     
    Accordingly,  the  Court  concludes  that  Plaintiff  has  not  presented  prima  facie 
evidence that Sheriff Stuart acted with deliberate disregard of her rights, and her motion is 
likewise denied with respect to her request to seek punitive damages in connection with 
her false-imprisonment claim against Sheriff Stuart.                      

    D. Summary                                                           

    In sum, Plaintiff’s motion is granted with respect to her proposed equal-protection 
claim7 against the County Defendants and request to seek punitive damages in connection 
with  her  §  1983  claims  against  Officer  Oman  and  Sheriff  Stuart  in  their  individual 
capacities.  Plaintiff shall specify that such damages are being sought only with respect to 
these claims and in this capacity.  Plaintiff’s motion is denied with respect to her request 
to seek punitive damages in connection with her false-imprisonment claim. 


7 The Court encourages Plaintiff to verify the terminology employed.  See supra n.4. 
                           IV. ORDER                                     
    Based on the foregoing, and all of the files, records, and proceedings herein, IT IS 

HEREBY ORDERED that:                                                      
    1.  Plaintiff’s Motion for Leave to Amend Complaint and Modify the Pretrial 
      Scheduling Order (ECF No. 59) is GRANTED IN PART and DENIED IN     
      PART as set forth herein.                                          

    2.  Plaintiff shall file Hearing Exhibits 4, 5, and 6 within 7 days from the date of 
      this Order.                                                        

    3.  Plaintiff shall file a Second Amended Complaint consistent with this Order and 
      in substantially the same form as the Proposed Second Amended Complaint for 
      Damages, Punitive Damages and Other Relief (ECF No. 59-1) within 7 days 
      from the date of this Order.                                       

    4.  All prior consistent orders remain in full force and effect.     

    5.  Failure to comply with any provision of this Order or any other prior consistent 
      Order shall subject the non-complying party, non-complying counsel and/or 
      the party such counsel represents to any and all appropriate remedies, sanctions 
      and the like, including without limitation: assessment of costs, fines and 
      attorneys’ fees and disbursements; waiver of rights to object; exclusion or 
      limitation of witnesses, testimony, exhibits and other evidence; striking of 
      pleadings; complete or partial dismissal with prejudice; entry of whole or 
      partial default judgment; and/or any other relief that this Court may from time 
      to time deem appropriate.                                          




Dated: September      16    , 2019      s/ Tony N. Leung                                      
                                  Tony N. Leung                          
                                  United States Magistrate Judge         
                                  District of Minnesota                  

                                  Parada v. Anoka County et al.          
                                  Case No. 18-cv-795 (JRT/TNL)           

Reference

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