Kasso v. City of Minneapolis

Background

Leila Kasso, a Minneapolis Police Department (MPD) officer, filed this lawsuit on October 10, 2025, alleging unlawful treatment by MPD superiors in April 2021, during the Derek Chauvin criminal trial. She named the City of Minneapolis as the sole defendant. She had previously filed a Charge of Discrimination with the Equal Employment Opportunity Commission (EEOC), and on July 10, 2025, received a Notice of Right to Sue — which gave her 90 days to file a lawsuit.

Kasso's central allegations involve Christy Nelson, an MPD employee who sat on a promotion board. Kasso alleged that around April 19, 2021, Nelson ordered her to an underground basement five levels below ground with no backup, internet, radio communication, or means to call for help, despite the foreseeability of civil unrest, while other light-duty officers were assigned to safe, monitored locations. Nelson also allegedly ordered Kasso to wear a full MPD uniform in violation of MPD's light-duty policy. Kasso further alleged that Nelson unlawfully accessed her confidential medical information without consent and used it to influence adverse employment decisions, that she was denied promotions because of her disability, that her transfer request was denied without justification, and that her workplace was physically sabotaged (office door removed, protective window shield torn down, desk ransacked).

Claims Asserted

Kasso asserted five counts: (1) ADA discrimination; (2) ADA retaliation; (3) ADA confidentiality violation; (4) equal protection violation under 42 U.S.C. § 1983; and (5) intentional infliction of emotional distress (IIED) under state law. She sought compensatory damages, punitive damages, and attorney's fees.

Legal Standard

The City moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally plausible claim. Under Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, a complaint must contain enough factual matter — not just conclusory statements — to make the claimed relief plausible. Because Kasso appeared to be proceeding without counsel (pro se), the court construed her complaint liberally, but still required sufficient facts.

Analysis of Each Claim

Count I: ADA Discrimination

To state an ADA discrimination claim, a plaintiff must allege: (1) she has a qualifying disability; (2) she is a qualified individual under the ADA; and (3) she suffered an adverse employment action because of her disability. The ADA defines disability as a physical or mental impairment that substantially limits a major life activity, a record of such impairment, or being regarded as having such an impairment.

The court found that Kasso's complaint contained only conclusory statements that she had a disability — for example, that she was "recovering from a disability" — without describing any symptoms, diagnosis, or treatment. Because no facts supported a finding of a qualifying disability, this claim failed at the threshold.

Count II: ADA Retaliation

An ADA retaliation claim requires: (1) engagement in protected activity (such as requesting a reasonable accommodation or opposing discriminatory conduct); (2) an adverse employment action; and (3) a causal connection between the two. The complaint alleged that Kasso "was denied reasonable accommodation required under the ADA," but the court found this insufficient to plausibly allege that Kasso actually requested an accommodation — a necessary predicate. Without a plausible allegation of protected activity, the retaliation claim failed.

Count III: ADA Confidentiality Violation

The ADA restricts employer access to and disclosure of employee medical information (42 U.S.C. § 12112(d)). A plaintiff must also show that the violation caused an adverse employment action. Kasso's complaint alleged only, in a single conclusory sentence, that Nelson accessed her medical information unlawfully and used it to influence adverse employment actions. The complaint supplied no facts about what information was accessed, how it was accessed, how it was used, or what the resulting adverse actions were. The court held this was insufficient.

Count IV: Equal Protection / Section 1983

Because the City was the sole defendant, the court analyzed the § 1983 equal protection claim as a Monell claim — named for Monell v. Department of Social Services, 436 U.S. 658 (1978). Under Monell, a municipality (city government) cannot be held liable merely because one of its employees committed a constitutional violation; instead, the plaintiff must show the violation resulted from: (1) an official municipal policy; (2) an unofficial custom; or (3) a deliberately indifferent failure to train or supervise employees.

The court found that Kasso's complaint did not identify or describe any such policy, custom, or failure to train or supervise. Even assuming individual MPD employees violated her constitutional rights, the claim against the City itself was inadequately pleaded.

Count V: Intentional Infliction of Emotional Distress (State Law)

Federal courts may exercise supplemental jurisdiction — the authority to hear related state law claims alongside federal claims — under 28 U.S.C. § 1367(a). However, when all federal claims are dismissed, a court may decline to exercise that authority over remaining state law claims under § 1367(c)(3). Because all four federal claims were dismissed, the court declined to hear the IIED claim and dismissed it without prejudice.

Disposition and Warning

Judge Menendez granted the City's Motion to Dismiss in full. The entire complaint was dismissed without prejudice — meaning Kasso is not automatically barred from refiling a corrected complaint.

However, the court issued a notable caution. The City had argued — and the court found it a serious concern — that Kasso's complaint was filed outside the 90-day window that begins upon receipt of a right-to-sue letter from the EEOC. Kasso received her right-to-sue notice on July 10, 2025, and filed this lawsuit on October 10, 2025. The court noted that if this filing was in fact untimely under the ADA's statute of limitations, any refiled complaint asserting the same time-barred ADA claims would likely be a futile endeavor and could implicate Rule 11(b)(2), which prohibits frivolous filings. The court did not rule on the timeliness issue, but flagged it prominently for Kasso's awareness.