Loyd v. Schmitt
Minnie Loyd v. Jason Schmitt, in his individual and official capacities; and City of Minneapolis
- Laura Provinzino
- 0:24-cv-01391
- U.S. District Court · District of Minnesota
- 19
In Loyd v. Schmitt, Judge Provinzino granted summary judgment for defendants Officer Jason Schmitt and the City of Minneapolis, dismissing with prejudice all of plaintiff Minnie Loyd's Fourth Amendment claims arising from search warrants obtained during a drug trafficking investigation, finding that the admitted inaccuracies in the warrant applications were the result of innocent mistakes or negligence rather than deliberate or reckless falsehoods.
People who are subjects of police investigations and whose property or phone records are covered by search warrants obtained during criminal investigations of others, particularly where those warrants may contain inaccuracies. Also relevant to police officers who use template-based warrant applications, and to municipalities facing civil rights suits arising from warrant-based searches.
What happened
In Loyd v. Schmitt (Case No. 24-cv-1391), Minnie Loyd sued Minneapolis police officer Jason Schmitt and the City of Minneapolis under 42 U.S.C. § 1983, a federal law allowing people to sue government officials for violating their constitutional rights. Loyd claimed that Officer Schmitt violated her Fourth Amendment right against unreasonable searches when he obtained several tracking warrants — for two cell phones (the '1225 phone' and the '9886 phone'), her Porsche, and her Audi — during a 2019 drug trafficking investigation targeting a man named Kevin Green, and that those warrants contained false statements. Loyd sought money damages, a court declaration that her rights were violated, and an order requiring the City to improve its officer training on warrant applications.
The case arose because Officer Schmitt, while investigating Green for narcotics trafficking, obtained warrants to track Green's phones and cars belonging to Loyd, who was connected to Green. Several of the warrant applications contained inaccurate statements. For the phone tracking warrants, Officer Schmitt admitted the errors but explained they resulted from copying over standard law enforcement templates and using a 'find and replace' function in Microsoft Word without catching all the resulting mistakes. A federal magistrate judge who previously reviewed these warrants in Green's criminal case concluded that even stripping out the inaccurate statements, enough legitimate evidence remained to support the warrants. The Porsche warrant was never carried out — no tracker was ever placed on the car. The Audi warrant contained no alleged false statements. Loyd never responded to the defendants' motion for summary judgment, never provided required initial disclosures, and never sought any discovery.
Judge Provinzino granted the defendants' motion for summary judgment and dismissed the entire case with prejudice, meaning Loyd cannot refile these claims. The court ruled that Loyd's requests for injunctive and declaratory relief failed because those remedies address future harm, and Loyd's injuries were entirely in the past with no ongoing threat. On the core Fourth Amendment claims, the court found no genuine dispute that the inaccuracies in the phone warrants were innocent mistakes or negligence — not the deliberate or reckless falsehoods required to prove a constitutional violation. The Porsche warrant claim failed because the warrant was never executed and no actual search occurred. The Audi warrant claim failed because Loyd identified no false statements in that application. Because the individual claims against Officer Schmitt failed, the related claim against the City also failed as a matter of law.
The detailed version
Loyd v. Schmitt — Detailed Summary
- U.S. District Court, District of Minnesota **Case No.:** 24-cv-1391 (LMP/JFD)
- Laura M. Provinzino, United States District Judge
- February 17, 2026
- Defendants' Motion for Summary Judgment GRANTED; complaint DISMISSED WITH PREJUDICE
Parties - Plaintiff: Minnie Loyd - Defendants: Jason Schmitt, in his individual and official capacities; and City of Minneapolis
Background Facts
In 2019, Officer Jason Schmitt of the Minneapolis Police Department was investigating weapons, violent crime, and narcotics. In January 2019, he arrested an individual who identified a large-scale heroin dealer known as "Stunna," said to drive a rose-colored Porsche and use a phone number ending in 1225 (the "1225 phone"). Officer Schmitt identified "Stunna" as Kevin Green through Facebook.
In February 2019, Officer Schmitt observed Green driving a rose-colored Porsche registered to Loyd. He observed behavior consistent with drug trafficking, leading him to apply for a warrant to place a GPS tracker on the Porsche. The warrant issued but was never executed because Officer Schmitt could not locate the Porsche again.
Officer Schmitt applied for a warrant to track the 1225 phone on March 6, 2019, using a template developed by the Minnesota Bureau of Criminal Apprehension (BCA) and the Federal Bureau of Investigation (FBI). The application inadvertently included the statement: "Both the CRI and CI have provided information in the past that has been reliable, accurate and confirmable" — which was not accurate. (A "CRI" is a confidential reliable informant with a proven track record; a "CI" is a confidential informant whose reliability is not vouched for.) A state court judge signed the warrant. On May 1, 2019, Officer Schmitt applied for an extension to this warrant, using the original application as a template, and the inaccurate CRI/CI statement carried over. A state court judge granted the extension.
Officer Schmitt then sought a warrant for a new phone number ending in 9886 (the "9886 phone"), using the 1225 phone extension application as a template and employing Microsoft Word's "find-and-replace-all" function to substitute "9886 phone" for "1225 phone" throughout. This process introduced three admitted inaccuracies: (1) that a confidential informant had identified the 9886 phone as associated with Green (the find-and-replace function changed a correct statement about the 1225 phone); (2) that "a current court order is in place on this cell phone" which "was expiring" (an inadvertent holdover from the extension application); and (3) that the 9886 phone belonged to Loyd and was used to rent a Maserati on June 10, 2019 (Officer Schmitt believed this based on information from a car rental agency, but later learned it was incorrect). A state court judge signed the 9886 phone warrant on June 11, 2019.
On June 13, 2019, Officer Schmitt obtained and executed a tracking warrant for an Audi registered to Loyd. That warrant was used to monitor the Audi's location.
Federal narcotics charges were brought against Green on August 13, 2019. In Green's criminal proceedings, Green moved to suppress evidence from the warrants and sought a Franks hearing (named after Franks v. Delaware, 438 U.S. 154 (1978), which held that warrants based on affidavits containing deliberate falsehood or reckless disregard for the truth violate the Fourth Amendment). A Franks hearing was held before U.S. Magistrate Judge Elizabeth Cowan Wright on May 6, 2021, at which Officer Schmitt testified about all of the above. Magistrate Judge Wright largely recommended denial of Green's suppression motions, concluding that even with inaccuracies removed, probable cause supported the 9886 phone warrant. That recommendation was largely adopted by the presiding district judge (the 9886 phone warrant motion was denied as moot because the government did not intend to use that evidence). Green was convicted and sentenced to 180 months in prison.
Loyd filed this Section 1983 lawsuit on April 17, 2024. After filing, Loyd failed to provide mandatory initial disclosures, sought no discovery, failed to respond to the defendants' summary judgment motion, and failed to respond to the court's order to show cause why the motion should not be decided without her input.
Claims
- Section 1983 / Fourth Amendment claim against Officer Schmitt (individual capacity): Alleging he violated Loyd's Fourth Amendment rights by including false statements in the warrant applications.
- Section 1983 / Fourth Amendment claim against Officer Schmitt (official capacity): Treated as a Monell claim against the City.
- Monell claim against the City of Minneapolis: Alleging the constitutional violation resulted from an official policy, unofficial custom, or deliberate indifference in training/supervision.
- Requests for injunctive and declaratory relief: Seeking a declaration of unconstitutionality and an order requiring improved officer training.
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. Where a party fails to respond to a summary judgment motion, the court may treat the movant's asserted facts as undisputed.
Fourth Amendment / Franks standard
A warrant based on an affidavit containing deliberate falsehood or reckless disregard for the truth violates the Fourth Amendment and can give rise to Section 1983 liability. However, an innocent mistake or negligence does not constitute reckless or deliberate falsehood. Even if a warrant contains such falsehoods, no Fourth Amendment violation occurs unless the warrant's remaining accurate content is insufficient to establish probable cause.
Standing for injunctive/declaratory relief
A plaintiff seeking forward-looking relief must show an ongoing injury or immediate threat of future injury; past injuries alone are insufficient.
Monell liability
A city cannot be held liable under Section 1983 simply because it employs a wrongdoer. Liability attaches only if a constitutional violation resulted from an official policy, unofficial custom, or deliberate indifference in training or supervision. Importantly, municipal liability requires a finding of individual liability on the underlying claim first.
Holdings and Analysis
I. Standing — Injunctive and Declaratory Relief Dismissed
The court dismissed Loyd's requests for injunctive and declaratory relief for lack of standing. The alleged conduct occurred in 2019 as part of a concluded investigation. Loyd's complaint itself used past tense to describe her injuries. There was no evidence of an ongoing or imminent injury. To the extent Loyd sought relief on behalf of others not before the court, she lacked standing to assert third-party rights.
II. Section 1983 Claim Against Officer Schmitt — Dismissed
1225 Phone Warrants: As a threshold matter, there was no evidence the 1225 phone belonged to Loyd; the record suggested it belonged to Green, undermining any claim of a reasonable expectation of privacy. Even assuming Loyd had such an interest, the inaccurate CRI/CI statement was an innocent mistake — a holdover from a standard law enforcement template that Officer Schmitt forgot to delete. The court credited Officer Schmitt's uncontradicted Franks hearing testimony and held this rose only to negligence, not deliberate or reckless falsehood, citing analogous cases involving template copy-and-paste errors.
9886 Phone Warrant: The court analyzed all four challenged statements: - The confidential informant statement was the unintended product of the find-and-replace-all function — at most negligence, not deliberate falsehood. - The "current court order" statement was an inadvertent holdover from the template — again, at most negligence. - The Maserati rental statement was believed accurate when written, based on information from a car rental agency. Under Franks, a statement is "truthful" if the affiant reasonably believed it; the fact it proved incorrect does not establish knowing or reckless falsity. - The statement that Green "is rarely observed without Loyd being present" was not shown to be false. Loyd pointed only to Green's April 19, 2019 traffic stop where she was not present, but one absence does not contradict a statement of general frequency.
Additionally, Magistrate Judge Wright's Franks proceeding in Green's case had already determined that even with the inaccuracies removed, the 9886 phone warrant was still supported by probable cause. Loyd offered nothing to counter this. The court held this independently defeated any Fourth Amendment violation claim.
Porsche Warrant: The warrant was never executed — no GPS tracker was ever placed on the Porsche. The Fourth Amendment protects against unreasonable searches and seizures; because no search occurred, Loyd suffered no Fourth Amendment injury from the issuance of the Porsche warrant alone.
Audi Warrant: Loyd identified no false statements in the Audi warrant application, and none appeared in the record. Green, in his criminal case, had challenged the Audi warrant only on probable cause grounds (not false statements). Without a false statement, a Franks-based Fourth Amendment claim fails.
Because Loyd raised no genuine dispute of material fact as to deliberate or reckless falsehood in any of the warrants, the Section 1983 claim against Officer Schmitt in his individual capacity was dismissed.
III. Monell Claim Against the City — Dismissed
Because the court dismissed all individual-capacity claims against Officer Schmitt, no underlying constitutional violation was established. Under controlling Eighth Circuit precedent, municipal liability under Monell cannot attach without a predicate finding of individual liability. The Monell claim was therefore dismissed as well.
Disposition
- Defendants' Motion for Summary Judgment: GRANTED - Loyd's complaint: DISMISSED WITH PREJUDICE (Loyd cannot refile these claims) - Judgment to be entered accordingly.
Reviewer note from the AI+
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.