Baker v. Holtz
Dean Lee Baker, Jr. v. Cody Alan Holtz, in his individual capacity, and Morrison County
- Katherine Menendez
- 0:25-cv-00430
- U.S. District Court · District of Minnesota
- 8
In Baker v. Holtz, Judge Menendez granted summary judgment in favor of Deputy Cody Alan Holtz and Morrison County, dismissing with prejudice Dean Lee Baker Jr.'s claims that a traffic stop and subsequent arrest violated his Fourth Amendment rights and constituted false arrest under Minnesota law.
Individuals who have been stopped by law enforcement officers and who claim the stop lacked legal justification; people bringing civil rights claims under 42 U.S.C. § 1983 against police officers and local governments for alleged Fourth Amendment violations involving traffic stops.
What happened
In Baker v. Holtz (No. 25-cv-430), Dean Lee Baker, Jr. sued Morrison County Sheriff's Deputy Cody Alan Holtz and Morrison County, claiming that Deputy Holtz stopped Baker's vehicle on August 4, 2023, without a lawful basis, violating his Fourth Amendment right against unreasonable seizures. Baker also brought a Minnesota state-law claim for false arrest arising from his subsequent arrest for driving while impaired. The case began as a motion for judgment on the pleadings but was converted to a motion for summary judgment — meaning a ruling based on undisputed facts without a trial — after the court determined that evidence outside the original complaint needed to be considered.
The central factual dispute was whether Deputy Holtz had checked Baker's license plate and learned of his suspended license before initiating the stop. Baker alleged in his complaint that no such check occurred. However, squad-car video showed Deputy Holtz behind Baker's vehicle at 9:22 p.m., and Minnesota Bureau of Criminal Apprehension (BCA) records showed that Holtz ran the plate at 9:21:37 p.m., receiving results showing the registered owner's license was suspended at 9:21:39 p.m. The stop was initiated just before 9:23 p.m. Baker was given the opportunity to conduct additional discovery to challenge the authenticity of these records but chose not to submit any additional evidence or argument.
Judge Menendez found no genuine dispute of material fact — meaning no real factual disagreement a jury would need to resolve — and ruled that Deputy Holtz had reasonable suspicion to make the traffic stop based on the suspended license information obtained before the stop. Because Baker himself conceded the stop would be lawful if Holtz had that information beforehand, and because the evidence confirmed Holtz did, the Fourth Amendment claim failed. The false arrest claim also failed because Baker's only argument was that the arrest stemmed from an unlawful stop — a premise the court rejected. Judge Menendez granted summary judgment to both defendants and dismissed the entire case with prejudice, barring Baker from refiling these claims.
The detailed version
- Baker v. Holtz, No. 25-cv-430 (KMM/LIB), United States District Court for the District of Minnesota
- Katherine Menendez, United States District Judge
- October 9, 2025
Background and Procedural History
Plaintiff Dean Lee Baker, Jr. filed suit on February 4, 2025, under 42 U.S.C. § 1983 — the federal civil rights statute that allows individuals to sue government officials for constitutional violations — against Morrison County Sheriff's Deputy Cody Alan Holtz (in his individual capacity) and Morrison County. Baker alleged that on August 4, 2023, Holtz stopped his vehicle without probable cause or reasonable suspicion, violating the Fourth Amendment's prohibition on unreasonable seizures. Baker also asserted a Minnesota state-law claim for false arrest in Count Two, alleging the arrest was willful, malicious, and without legal basis, and seeking to hold Morrison County vicariously liable.
Defendants filed their Answer on May 5, 2025, attaching body-camera video, squad-car video, and other records. They moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c), arguing Deputy Holtz had a lawful basis for the stop because he had run the license plate and learned the registered owner had a suspended license before initiating the stop.
Baker opposed the motion, arguing the video was inconclusive, challenging the authenticity of documents, arguing certain materials constituted inadmissible hearsay (out-of-court statements offered for their truth), and questioning whether such outside materials could be considered under Rule 12. Defendants filed a reply with additional evidence including declarations certifying BCA records.
At a July 9, 2025 hearing, the court expressed skepticism about considering documents outside the pleadings under Rule 12(c) but noted the documents raised serious concerns about the viability of Baker's claims. The court converted the motion to one for summary judgment under Federal Rule of Civil Procedure 56, citing Whatley v. Canadian Pacific Railway Ltd., 904 F.3d 614 (8th Cir. 2018). Baker was given until August 27, 2025, to conduct limited discovery and either seek dismissal or request a status conference.
On August 27, 2025, Baker's counsel notified the court by email that they did not intend to submit additional materials, and subsequently filed a letter agreeing to proceed on the existing record. The court treated the parties' existing briefs — though framed around the Rule 12(c) standard — as arguments under Rule 56, in the interest of judicial economy.
Legal Standards
Summary judgment is appropriate when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). A dispute is "genuine" only if a reasonable jury could return a verdict for the non-moving party. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The court views facts in the light most favorable to the non-moving party. Once the moving party meets its burden, the opposing party must present admissible evidence of specific facts creating a genuine issue; mere allegations are insufficient.
Count One — Fourth Amendment Traffic Stop
A traffic stop is a seizure under the Fourth Amendment. It is lawful if supported either by probable cause of a traffic violation or by reasonable articulable suspicion of criminal activity. Under the totality-of-the-circumstances test, an officer must have a particularized and objective basis for suspecting wrongdoing — more than a mere hunch, but less than probable cause. Sturgeon v. Faughn, 36 F.4th 804, 808 (8th Cir. 2022).
Baker himself conceded that if Holtz had run the plate and learned of the suspended license before the stop, there would be reasonable suspicion. Under Minnesota law, driving with a suspended license is a misdemeanor. Minn. Stat. § 171.24, subd. 1. Under Kansas v. Glover, 589 U.S. 376 (2020), when an officer lacks information negating the inference that the registered owner is driving, a stop based on a suspended/revoked license is reasonable.
The BCA records showed Holtz ran the plate at 9:21:37 p.m. and received a result of "STATUS:SUSPENDED" at 9:21:39 p.m. Squad-car video showed Holtz behind Baker's vehicle at 9:22 p.m., and the stop was initiated just before 9:23 p.m. No evidence in the record suggested that the driver was not the registered owner, negating the lawful inference. Baker had the opportunity to conduct discovery challenging the authenticity of the BCA records but declined to do so. The court found no genuine dispute of material fact and granted summary judgment on Count One to Deputy Holtz.
Count Two — False Arrest (Minnesota State Law)
The court construed Count Two as a Minnesota state-law false arrest claim (not a Fourth Amendment claim, as Baker did not brief a federal constitutional claim regarding the arrest). Under Minnesota law, false arrest requires a showing that a defendant arrested someone without proper legal authority. Baribeau v. City of Minneapolis, 596 F.3d 465, 481 (8th Cir. 2010). An arrest is lawful if supported by probable cause.
Defendants argued Deputy Holtz observed signs of impairment and Baker failed field sobriety tests during the stop, providing probable cause to arrest him for driving while impaired under Minn. Stat. § 169A.20, subd. 1. Baker's only response was that the arrest was unlawful because it flowed from an unlawful stop. Because the court found the stop was lawful, Baker's argument collapsed. The court also noted, in a footnote, that to the extent Baker argued Holtz did not independently develop probable cause during the stop, the record evidence (squad-car video from 9:23–9:49 p.m.) showed otherwise. Summary judgment was granted to both defendants on Count Two.
Disposition
Defendants' Motion for Summary Judgment (Dkt. No. 9) was GRANTED. The case was DISMISSED WITH PREJUDICE — meaning Baker cannot refile these claims.
Reviewer note from the AI+
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.