Hoel v. Prouse
Robert Brooks Hoel v. Alexander Prouse, Deputy – ID #5368 – sued in both his individual and official capacities; Joseph Carter, Officer – ID #121 – sued in both his individual and official capacities; Doe 1; City of Proctor; St. Louis County
- Eric Tostrud
- 0:25-cv-02342
- U.S. District Court · District of Minnesota
- 19
In Hoel v. Prouse, Judge Tostrud allowed Robert Brooks Hoel's claims of unlawful seizure, excessive force, conversion, and malicious prosecution to move forward against the defendant officers and St. Louis County while dismissing — without prejudice — his First Amendment retaliation, illegal search, civil-rights conspiracy, failure-to-prevent, municipal liability, and emotional distress claims.
People who have been stopped, seized, or physically handled by law enforcement officers without apparent justification; individuals whose property was taken or damaged by officers; pro se litigants asserting civil rights claims; and civil rights plaintiffs who need to understand the level of factual detail required to state claims for retaliation, conspiracy, or municipal liability under federal law.
What happened
In Hoel v. Prouse, pro se (self-represented) plaintiff Robert Brooks Hoel sued St. Louis County Sheriff's Deputy Alexander Prouse, City of Proctor Officer Joseph Carter, an unknown officer ('Doe 1'), the City of Proctor, and St. Louis County, alleging that on March 10, 2022, officers illegally seized him while he was filling water jugs at a public well, used excessive force against him, searched his vehicle without a warrant, destroyed his personal property including two phones and religious items, and then charged him with a misdemeanor that was later dropped. He brought ten claims under federal civil-rights law and Minnesota state law, seeking money damages, return of his property, and a court order requiring the municipal defendants to improve officer training and oversight.
The defendants moved to dismiss all claims, arguing in part that the officers were shielded from suit by 'qualified immunity' — a legal doctrine that protects government officials from personal liability unless they violated a clearly established legal right — and that the complaint failed to adequately allege facts supporting each claim. The court rejected the defendants' attempt to use a police report attached to the complaint to contradict Hoel's own allegations, holding that at this early stage the court must accept the plaintiff's factual allegations as true. The court found that Hoel's allegations — that he was lawfully present at a public well, had done nothing to justify suspicion, and fully complied with officer commands before being forcibly removed from his vehicle and physically thrown against it — were enough to allow his unlawful seizure and excessive force claims to survive. The court also allowed his Minnesota state law claims for conversion (unlawful taking of property) and malicious prosecution to proceed, noting that the defendants did not contest those claims on their merits.
Judge Tostrud dismissed six claims without prejudice, meaning Hoel may seek permission to refile them with better supporting facts. The First Amendment retaliation claim failed because the complaint did not identify which specific officer actions were taken in retaliation for Hoel's recording activity or allege any facts connecting retaliatory motive to those actions. The search and property-destruction claim failed because the complaint did not explain how the vehicle search was conducted or why it violated the Constitution. The civil-rights conspiracy claim under 42 U.S.C. § 1985(3) failed because the complaint alleged no facts showing the defendants agreed to conspire or acted with animus toward Hoel as a member of a protected class; the related 'failure to prevent' claim under § 1986 fell with it. The municipal liability claim failed because Hoel offered only a legal conclusion that the cities failed to train their officers, without factual support. Finally, the intentional infliction of emotional distress claim was time-barred: Minnesota law requires such claims to be filed within two years of the harmful act, the incident occurred in March 2022, and Hoel did not file until June 2025.
The detailed version
Case: Hoel v. Prouse et al., File No. 25-cv-2342 (ECT/LIB), United States District Court, District of Minnesota. Judge: Eric C. Tostrud. Opinion and Order dated October 30, 2025.
Background and Facts Pro se plaintiff Robert Brooks Hoel alleges that on March 10, 2022, at approximately 10:30 p.m., he was lawfully present at a public well in Midway Township, Minnesota, filling water jugs. St. Louis County Sheriff's Deputy Alexander Prouse approached and demanded identification. Hoel told the officer he did not wish to speak further because it was freezing cold and he needed to warm up, then entered a vehicle and began recording the encounter on his phone. Deputy Prouse and City of Proctor Officer Joseph Carter allegedly opened the car door without lawful cause, forcibly removed Hoel, and threw his spiritual tobacco bag and ceremonial supplies — described as items of personal and religious significance — to the ground. Despite Hoel's full compliance with commands, the officers allegedly threw him against the vehicle, causing physical pain and destroying his tobacco and rolling machine. The officers seized his phone and stopped the recording. Hoel was handcuffed and detained in another vehicle without lawful justification. An unknown officer ('Doe 1') arrived and assisted in a warrantless search of Hoel's vehicle. Hoel received a citation for misdemeanor obstruction of justice under Minn. Stat. § 609.50, subdiv. 1(1), but the charge was later removed from all records without explanation. Deputy Prouse left the scene with Hoel's phones, returning later with one phone visibly damaged (screen shattered, casing cracked) and the second phone missing entirely.
Legal Standards Applied The court assessed two types of defense motions: a Rule 12(b)(6) motion to dismiss for failure to state a claim (filed by Carter and the City of Proctor) and a Rule 12(c) motion for judgment on the pleadings (filed by Prouse and St. Louis County), both evaluated under the same standard — whether the complaint states a facially plausible claim. Hoel's complaint was entitled to liberal construction as a pro se filing, though that standard does not excuse insufficient factual allegations. The court declined to consider facts described in the attached police report to the extent those facts contradicted the complaint's allegations, as doing so would violate the fundamental rule that a plaintiff's well-pleaded allegations are accepted as true at this stage.
Qualified Immunity Framework Because the police report could not be used to contradict the complaint, the court assessed qualified immunity — which shields government officials from personal liability unless they violated a clearly established constitutional right — solely on the face of the complaint. The relevant question was whether the allegations plausibly show a constitutional violation of clearly established law.
Claims Surviving Dismissal
1. Fourth Amendment unlawful seizure/arrest (Count I, § 1983): The complaint alleges Hoel was lawfully at a public well, had done nothing to arouse reasonable suspicion, and no Minnesota law criminalizing mere refusal to show identification to an officer in these circumstances was cited by defendants or found by the court. The court held the allegations plausibly show the officers lacked any justification — either probable cause for arrest or reasonable articulable suspicion for a brief investigatory ('Terry') stop — and that the relevant Fourth Amendment rules are clearly established. Qualified immunity does not bar this claim at this stage.
2. Fourth Amendment excessive force (Count II, § 1983): The complaint alleges the officers forcibly removed Hoel from the vehicle and threw him against it, causing physical pain, even though he was fully compliant and had done nothing to justify any use of force. Under Eighth Circuit precedent, it is clearly established that if a person is not suspected of a serious crime, is not threatening anyone, and is neither fleeing nor resisting arrest, more than minimal force is unreasonable. Qualified immunity does not bar this claim.
3. Conversion under Minnesota law (Count VIII): The complaint alleges Deputy Prouse left with Hoel's phones and returned with one damaged and one missing. The court found this sufficient to plausibly allege the elements of conversion — Hoel had a property interest, Prouse deprived him of it, one deprivation was permanent (unreturned phone), and there was no apparent legal justification. Importantly, Prouse did not argue for dismissal on the merits, only on supplemental jurisdiction grounds, which the court declined to accept given the surviving federal claims.
4. Malicious prosecution under Minnesota law (Count X): The complaint alleges Hoel fully complied with commands, was nonetheless charged with misdemeanor obstruction, and the charge was later dismissed without explanation. The elements of Minnesota malicious prosecution require the suit to have been brought without probable cause and with malicious intent, and to have terminated in the plaintiff's favor. The court noted that intent may be alleged generally under the Federal Rules of Civil Procedure and that Prouse did not contest this claim on the merits.
Claims Dismissed Without Prejudice
1. First Amendment retaliation (Count III, § 1983): To state this claim, a plaintiff must allege a protected activity, an adverse action that would chill a person of ordinary firmness, and a causal connection between the protected activity and the adverse action. The complaint did not identify which specific adverse actions were taken in retaliation for the recording activity or allege any facts tethering a retaliatory motive to those actions. Dismissed without prejudice.
2. Fourth/Fourteenth Amendment illegal search and property destruction (Count IV, § 1983): The court treated this as a Fourth Amendment claim. The complaint identified only a post-detention vehicle search but alleged no facts explaining how it was conducted or why it violated the Fourth Amendment, and did not connect alleged property damage to any specific search. Dismissed without prejudice.
3. Civil-rights conspiracy under 42 U.S.C. § 1985(3) (Count V): Section 1985(3) requires allegations of (1) a conspiracy, (2) for the purpose of depriving a person or class of equal protection of the laws, (3) an act in furtherance of the conspiracy, and (4) resulting injury. The complaint alleged no facts plausibly showing an agreement among defendants to conspire, and no facts showing class-based animus (that defendants targeted Hoel because of his membership in a protected class). Dismissed without prejudice.
4. Failure to prevent civil rights violations under 42 U.S.C. § 1986 (Count VI): A valid § 1985 conspiracy claim is a prerequisite to a § 1986 claim. Because Count V was dismissed, Count VI necessarily fails. Dismissed without prejudice.
5. Municipal liability under Monell v. Department of Social Services (Count VII, § 1983): Under Monell, a city or county cannot be held liable for a civil rights violation simply because it employed the wrongdoer; the plaintiff must show the violation resulted from an official policy or custom. The complaint alleged only that the municipal defendants 'failed to train, supervise, and discipline' their officers — a legal conclusion unsupported by specific factual allegations. Dismissed without prejudice.
6. Intentional infliction of emotional distress under Minnesota law (Count IX): Minnesota imposes a two-year statute of limitations on this claim, which accrues on the date of the tortious act. The alleged acts occurred on March 10, 2022; Hoel filed suit on June 4, 2025 — more than 14 months after the limitations period expired in March 2024. The complaint alleges no basis to pause (toll) the limitations period. Dismissed without prejudice.
Disposition Both defense motions were granted in part and denied in part. Counts III, IV, V, VI, VII, and IX were dismissed without prejudice — meaning Hoel may seek leave from the court to file an amended complaint correcting the identified deficiencies. Counts I, II, VIII, and X survive, as does Count VI only to the extent that the § 1986 claim might be saved by an amended § 1985 allegation. The court noted that dismissal with prejudice (permanently barring refiling) would be appropriate only for persistent pleading failures after prior opportunities to amend, which have not occurred here.
Reviewer note from the AI+
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.