Groschen v. Kopel
- Jeffrey Bryan
- 0:25-cv-01691
- U.S. District Court · District of Minnesota
- 7
In Groschen v. Kopel, Judge Jeffrey M. Bryan dismissed all claims brought by self-represented plaintiff Steven Groschen against two Woodbury police officers, ruling that his Fourteenth Amendment and federal criminal statute claims are permanently barred while his Fourth Amendment claim is dismissed but may potentially be refiled with more factual detail.
Self-represented individuals (particularly those advancing sovereign-citizen legal theories) who sue police officers under federal civil rights law following traffic stops; police officers facing § 1983 suits for conducting traffic stops based on vehicle registration and licensing violations.
What happened
In Groschen v. Kopel, Steven Groschen, who identifies as a 'sovereign citizen,' sued two Woodbury, Minnesota police officers — Alana Kopel and Robin Kivel — after a traffic stop on August 18, 2024. Officer Kopel pulled Groschen over because his vehicle lacked proper registration or license plates. Groschen refused to provide identification or insurance information, was arrested, and was later charged with several traffic violations, though all charges were eventually dismissed. Groschen then sued the officers in federal court, claiming they violated his constitutional rights and a federal criminal law, seeking more than $2 million in damages.
Groschen made three legal claims. First, he argued the officers violated his Fourteenth Amendment right to travel by enforcing state vehicle registration and licensing laws, asserting those laws only apply to commercial drivers, not private individuals like himself. Second, he claimed the officers violated his Fourth Amendment right against unreasonable searches and seizures when they searched him during his arrest and took his personal property. Third, he claimed the officers violated a federal criminal law, 18 U.S.C. § 242, which prohibits government officials from depriving people of their civil rights under color of law.
Judge Jeffrey M. Bryan granted the officers' motion to dismiss all three claims. The court ruled that the Fourteenth Amendment claim fails because courts have repeatedly held that state vehicle registration, licensing, and insurance laws do not violate any constitutional right to travel — regardless of whether the driver is engaged in commercial activity. The Fourteenth Amendment claim was dismissed with prejudice, meaning Groschen cannot refile it. The Fourth Amendment claim was dismissed without prejudice — meaning Groschen could potentially refile — because his complaint contained only vague legal conclusions with no specific facts about what property was taken or why the search was unreasonable. Finally, Judge Bryan dismissed the federal criminal statute claim with prejudice because private individuals cannot sue under 18 U.S.C. § 242; only the federal government can bring charges under that law.
The detailed version
- Groschen v. Kopel, File No. 25-CV-01691 (JMB/SGE)
- Jeffrey M. Bryan, United States District Judge
- March 24, 2026
Background
On August 18, 2024, Woodbury Police Department Officer Alana Kopel conducted a traffic stop of Steven Groschen's vehicle due to a lack of proper registration or license plates. Groschen refused to provide identification or insurance information, asserting he had committed no crime. Officer Robin Kivel arrived on scene; Groschen continued to refuse. Kopel placed Groschen under arrest and a search of his person was conducted. He was later charged in Washington County District Court with failure to possess or display a driver's license, failure to carry proof of insurance, and failure to display vehicle registration. All charges were ultimately dismissed pursuant to a plea agreement.
Groschen, proceeding without a lawyer (self-represented) and self-identified as a sovereign citizen, filed an Amended Complaint in federal court against Kopel and Kivel individually. The court construed his constitutional claims as brought under 42 U.S.C. § 1983, the federal civil rights statute that allows individuals to sue government officials for constitutional violations committed under color of state law.
Claims Asserted:
- Fourteenth Amendment (right to travel/locomotion): Groschen argued that state vehicle licensing and registration laws violate his constitutional right to travel, asserting those laws apply only to commercial drivers and not to private individuals exercising their absolute right to use public roads.
- Fourth Amendment (unreasonable search and seizure): Groschen alleged the officers unlawfully searched his person upon arrest and illegally seized his personal property.
- 18 U.S.C. § 242 (federal criminal civil rights statute): Groschen alleged the officers violated his constitutional rights under color of law in violation of this federal criminal statute.
Legal Standard
The court applied the Rule 12(b)(6) standard for motions to dismiss for failure to state a claim. Under this standard, the court accepts all alleged facts as true and asks whether the complaint states a claim that is 'plausible on its face,' meaning the factual allegations allow a reasonable inference that the defendants are liable. Legal conclusions dressed up as factual allegations are not accepted as true.
Qualified Immunity
The court analyzed the § 1983 constitutional claims under the doctrine of qualified immunity, which protects government officials — including police officers — from personal liability unless their conduct violated a clearly established constitutional or statutory right that a reasonable person would have known about. The court addressed this at the pleading stage, asking whether the alleged facts plausibly state a claim and whether that claim asserts a violation of a clearly established right.
Fourteenth Amendment Ruling — Dismissed WITH Prejudice
The court rejected Groschen's sovereign-citizen-based right-to-travel theory, citing extensive precedent holding that state vehicle registration, licensing, and proof-of-insurance requirements do not unconstitutionally infringe on any right to travel, whether the driver is engaged in commercial or private activity. The court cited Eighth Circuit precedent (Hughes v. City of Cedar Rapids) and multiple District of Minnesota cases dismissing identical sovereign-citizen arguments. Because Groschen's claim necessarily required a finding that such state laws are unconstitutional — a position courts have uniformly rejected — the Amended Complaint failed to plead a viable constitutional right, let alone a clearly established one. This claim was dismissed with prejudice (no refiling allowed).
Fourth Amendment Ruling — Dismissed WITHOUT Prejudice
The court found Groschen's Fourth Amendment allegations were bare legal conclusions unsupported by specific facts. The complaint stated only that the officers 'searched' him and 'illegally seized my personal property' without identifying what property was taken or providing any factual basis for concluding the search or seizure was unreasonable. The court noted in a footnote that to the extent the complaint could be read to challenge the lawfulness of his arrest, that claim also fails, because the Fourth Amendment permits warrantless arrests based on probable cause — including for minor offenses — and the officers had reasonable grounds to suspect Groschen of violating Minnesota vehicle registration laws (Minn. Stat. § 169.79, subd. 1). This claim was dismissed without prejudice, meaning Groschen could potentially refile with sufficient factual allegations.
18 U.S.C. § 242 Ruling — Dismissed WITH Prejudice
The court dismissed this claim because 18 U.S.C. § 242 is a federal criminal statute and provides no private right of action — meaning a private individual cannot sue under it in a civil lawsuit. Only the United States government, acting as prosecutor, can bring charges under § 242. Groschen offered no response to this argument. The claim was dismissed with prejudice.
Disposition
Defendants' motion to dismiss (Doc. No. 27) was GRANTED in full. The court directed that judgment be entered accordingly.
Reviewer note from the AI+
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.