Sinclair v. Culbeaux

CASE: Kenya Lenee Sinclair v. Gustavo Culbeaux, in his individual and official capacities, Minnesota State Patrol, and State of Minnesota, Case No. 25-cv-2365 (LMP/ECW), U.S. District Court for the District of Minnesota. JUDGE: Laura M. Provinzino, United States District Judge.

BACKGROUND: On November 1, 2024, Trooper Gustavo Culbeaux observed a vehicle speeding on Interstate 35W and activated his emergency lights at 8:49 p.m. The vehicle, driven by Sinclair, did not pull over. After approximately two minutes, Trooper Culbeaux executed a Pursuit Intervention Technique (PIT) maneuver — a law-enforcement technique designed to cause a fleeing vehicle to spin to a stop — striking Sinclair's vehicle twice on the passenger side. The vehicle came to a stop without hitting any barriers or other vehicles. After stopping, Sinclair exited and refused to comply with commands to turn around for handcuffing, asserting that Trooper Culbeaux lacked 'jurisdiction' over her. She was eventually handcuffed when a second trooper arrived. Sinclair informed Trooper Culbeaux that her grandson was in the backseat; troopers retrieved the child, and medics evaluated him. Sinclair's daughter, the child's mother, arrived at 9:21 p.m. and took the child. Sinclair was transported to county jail, where Trooper Culbeaux removed her handcuffs after she agreed not to resist.

Sinclair, proceeding pro se (representing herself without an attorney), filed suit on June 6, 2025, asserting six claims: (1) a Section 1983 claim — a federal civil rights statute allowing suits against government officials for constitutional violations — alleging Fourth Amendment excessive force and unlawful seizure based on the PIT maneuver; (2) a Section 1983 Fourteenth Amendment substantive due process claim for violation of her right to family integrity by separating her from her grandson; (3) an ADA Title II claim for failure to provide reasonable accommodations for her physical and mental disabilities (including a missing left thumb, surgical damage to her left arm and back, PTSD, anxiety, and depression); (4) state-law battery; (5) state-law negligence; and (6) state-law intentional infliction of emotional distress. She sought money damages, injunctive relief against Minnesota State Patrol practices, and declaratory relief.

The court considered the complaint alongside squad car and body camera videos, which it found were 'necessarily embraced by the pleadings' and therefore reviewable on a motion to dismiss. Where Sinclair's factual allegations were directly contradicted by the video — such as her claim that Trooper Culbeaux struck her vehicle while she was already stopped, and her claim that troopers refused to check on her grandson — the court disregarded those allegations.

RULINGS:

1. SOVEREIGN IMMUNITY (Eleventh Amendment) — All Claims Against State of Minnesota, Minnesota State Patrol, and Trooper Culbeaux in His Official Capacity: The Eleventh Amendment generally bars private suits against states in federal court. The court held that the State of Minnesota and the Minnesota State Patrol (as an 'arm of the state') are immune from all claims. Official-capacity damages claims against Trooper Culbeaux are also barred. No exception applied: Congress has not abrogated Eleventh Amendment immunity for Section 1983 claims, Minnesota has not consented to suit under Section 1983, and the ADA's abrogation of immunity does not apply here because the conduct did not implicate access to judicial services, was not unconstitutional (as explained below), and Sinclair did not argue the 'congruent and proportionate' abrogation test. The Eleventh Amendment applies equally to pendant state-law claims. All claims against these defendants/in this capacity were DISMISSED.

2. PROSPECTIVE INJUNCTIVE AND DECLARATORY RELIEF Against Trooper Culbeaux in His Official Capacity: Under the Ex parte Young doctrine, a plaintiff may seek prospective injunctive relief against a state official in their official capacity without violating sovereign immunity. However, such relief must address an ongoing violation of federal law — not past wrongs. Because all of Sinclair's injuries stemmed from a single completed event (her November 1, 2024 arrest), and she alleged no ongoing violation, prospective injunctive and declaratory relief was unavailable. These claims were DISMISSED.

3. SECTION 1983 — FOURTH AMENDMENT (Excessive Force — PIT Maneuver) Against Trooper Culbeaux in His Individual Capacity: Trooper Culbeaux invoked qualified immunity, which shields government officials from personal liability unless they violated a 'clearly established' constitutional right. The court applied the two-step qualified immunity analysis: (1) whether a constitutional violation occurred, and (2) whether the right was clearly established at the time. The court found that the right to be free from a PIT maneuver in these circumstances was not clearly established, relying heavily on the Eighth Circuit's decision in Moore-Jones v. Quick, 909 F.3d 983 (8th Cir. 2018), which held that officers are justified in using some force — including a PIT maneuver — when a driver refuses to comply with orders to stop. Here, Sinclair drove for two minutes after Trooper Culbeaux activated his emergency lights (longer than in Moore-Jones), and Trooper Culbeaux struck the passenger side on a lightly trafficked exit ramp. The court also rejected Sinclair's argument (raised only in her opposition brief, not her complaint) that she was looking for a safer location to stop, noting that officers need not divine a suspect's subjective motivations. Trooper Culbeaux is entitled to qualified immunity; this claim was DISMISSED.

4. SECTION 1983 — FOURTH AMENDMENT (Excessive Force — Handcuffs) Against Trooper Culbeaux in His Individual Capacity: The court noted that Sinclair did not actually allege in her complaint that she was handcuffed or that she suffered any injury from handcuffing. To prevail on an excessive-force claim arising from handcuffing, a plaintiff must allege 'something more' than the de minimis (minimal) force inherent in any handcuffing. Because Sinclair failed to allege any force or injury from handcuffs, this claim was DISMISSED.

5. SECTION 1983 — FOURTEENTH AMENDMENT (Due Process / Family Integrity) Against Trooper Culbeaux in His Individual Capacity: Sinclair alleged violation of her 'parental interest and right to family integrity.' The court found two independent grounds for dismissal. First, the substantive due process right to family integrity belongs to parents, not grandparents. Sinclair is her grandson's grandmother, and courts — including, in dicta, the Eighth Circuit — have generally not recognized grandparents' due process rights to custody of grandchildren living with their parents. Sinclair did not allege that she had custody of or lived with her grandson. Second, even if she had such a right, the approximately 29-minute separation during her arrest was insufficient to plausibly allege a violation. The separation was necessitated by Sinclair's arrest, the child was cared for by troopers and medics, and his mother was contacted and arrived to retrieve him. The court noted that the Eighth Circuit has upheld far more prolonged separations (weeks to nearly two years) without finding due process violations. This claim was DISMISSED.

6. ADA TITLE II — Against Trooper Culbeaux in His Individual Capacity: Title II of the ADA prohibits disability discrimination by a 'public entity.' Under Eighth Circuit precedent, 'public entity' does not include individual employees. Sinclair therefore cannot bring a Title II ADA claim against Trooper Culbeaux personally. This claim was DISMISSED.

7. STATE-LAW CLAIMS (Battery, Negligence, Intentional Infliction of Emotional Distress) Against Trooper Culbeaux in His Individual Capacity: Having dismissed all federal claims, the court exercised its discretion under 28 U.S.C. § 1367(c)(3) to decline supplemental jurisdiction over the remaining state-law claims. These claims were DISMISSED WITHOUT PREJUDICE, meaning Sinclair may potentially refile them in Minnesota state court.

ADDITIONAL MATTERS: Sinclair's second application to proceed without prepaying fees (she had already been granted such status earlier in the case) was DENIED as moot. Sinclair's motion for post-conviction relief regarding her state criminal case was DENIED because the federal court lacks jurisdiction over state criminal proceedings; the court noted the motion may have been intended for Ramsey County District Court.

FINAL DISPOSITION: The complaint was DISMISSED WITHOUT PREJUDICE in its entirety. Judgment was ordered to be entered accordingly.