Dickson v. Jacob R. Spies
Brandon C. Dickson v. Jacob R. Spies, Richard L. Knoche, Kyle A. Pond, John K. Biederman, Aaron J. Pearson, Tony J. Partyka, and Benjamin M. Bauer, individually and in their official capacity as Minneapolis police officers; the City of Minneapolis; Hennepin County; and Jason Wong and Jason Majeski, individually and in their official capacity as Hennepin County Sheriff deputies
- Paul Magnuson
- 0:25-cv-04307
- U.S. District Court · District of Minnesota
- 12
In Dickson v. Spies, Judge Magnuson dismissed with prejudice all civil-rights claims brought by Brandon Dickson against Minneapolis police officers, Hennepin County deputies, and the City of Minneapolis arising from two traffic stops in 2019 and 2020.
People who have been stopped by police and believe the stop was racially motivated or lacked legal justification; plaintiffs asserting civil-rights claims under § 1983 against police officers and municipalities; anyone seeking to understand how courts evaluate qualified immunity, body-camera footage, and the standard for traffic-stop justification in the Eighth Circuit.
What happened
In Dickson v. Spies (Civ. No. 25-4307), Brandon Dickson sued several Minneapolis police officers, Hennepin County Sheriff's deputies, the City of Minneapolis, and Hennepin County over two traffic stops — one in November 2019 and one in August 2020 — alleging that officers targeted him as a Black man without lawful justification. He brought claims under 42 U.S.C. § 1983 (a federal law that allows people to sue government officials for violating their constitutional rights) for unreasonable search and seizure, First Amendment retaliation, excessive force, civil conspiracy, and a Monell claim (a theory that holds cities or counties liable for unconstitutional policies or practices).
The court found that the officers had at least reasonable suspicion — and in some instances probable cause — to initiate both traffic stops. In the 2019 stop, body-camera footage and Dickson's own statements showed he had been closely following the officers' squad car, which supports a traffic violation, and officers also suspected an illegal window tint. In the 2020 stop, Dickson's taillights were visibly out — a fact he later admitted — and he acknowledged he had no insurance, which independently justified a stop and potential arrest. The court concluded that the searches and brief use of handcuffs during both stops were reasonable, and that the limited physical force used during the 2020 stop was minimal. Because no constitutional violation was established, the conspiracy and Monell claims also failed.
Judge Paul A. Magnuson granted both Hennepin County's motion to dismiss and the City of Minneapolis's motion for judgment on the pleadings, ruling that all of Dickson's claims are barred by qualified immunity — a legal doctrine that protects government officials from lawsuits unless they clearly violated established law. The court also found that Dickson's allegations were contradicted by body-camera footage. The entire case was dismissed with prejudice, meaning Dickson cannot refile these claims in federal court.
The detailed version
- Dickson v. Jacob R. Spies · No. 0:25-cv-04307
- Paul Magnuson
- July 8, 2026
Background
Plaintiff Brandon C. Dickson filed suit against seven Minneapolis police officers (Jacob R. Spies, Richard L. Knoche, Kyle A. Pond, John K. Biederman, Aaron J. Pearson, Tony J. Partyka, and Benjamin M. Bauer), the City of Minneapolis, Hennepin County, and two Hennepin County Sheriff's deputies (Jason Wong and Jason Majeski), individually and in their official capacities. His claims arise from two separate traffic stops.
2019 Incident
On the evening of November 13, 2019, Officers Spies and Knoche initiated a traffic stop after Dickson was driving closely behind their squad car in North Minneapolis, eventually pulling into a Walgreens parking lot. Dickson alleged the officers were deliberately targeting Black men without lawful justification. Dickson exited his vehicle and refused multiple commands, including instructions to place his hands on the vehicle and behind his back. Officer Knoche placed his forearm against the back of Dickson's neck and shoulder area during the handcuffing effort. A protective sweep of Dickson's vehicle followed. Dickson was ultimately released; no citation was issued and no charges were filed.
2020 Incident
Around midnight on August 8, 2020, Deputies Wong and Majeski observed that several of Dickson's taillights were not illuminated and his rear license plate was not visible, and initiated a traffic stop in downtown Minneapolis. Dickson admitted he had no insurance, no title, and nothing bearing the vehicle's identification number. When asked about weapons, Dickson indicated he might have a carpenter's knife but could not identify its location. Officers then produced handcuffs; Dickson expressed reluctance but was handcuffed with assistance from Minneapolis officers Biederman, Bauer, and Partyka, who responded to a call for help with a Terry stop (a brief investigative detention). Deputy Majeski also believed Dickson admitted to having marijuana. After the vehicle identification number check came back clear, Dickson was released. He was not arrested, cited, or charged.
Claims
Dickson brought claims under 42 U.S.C. § 1983 for: (1) unreasonable search and seizure under the Fourth Amendment; (2) First Amendment retaliation; (3) excessive force; (4) civil conspiracy; and (5) a Monell claim against the City and County. Dickson withdrew his vicarious-liability claim and his request for prospective injunctive relief before briefing concluded.
Procedural Posture
Hennepin County moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) (lack of subject-matter jurisdiction) and 12(b)(6) (failure to state a claim). The City of Minneapolis moved for judgment on the pleadings under Rule 12(c). The court noted that the same standard governs both a Rule 12(b)(6) motion and a Rule 12(c) motion, and that body-camera footage submitted with the defendants' declarations was properly considered because it was necessarily embraced by the pleadings.
Analysis
Qualified Immunity
Qualified immunity shields government officials from suit unless their conduct violates a clearly established statutory or constitutional right of which a reasonable person would have known. The court found that no clearly established law would have put any defendant on notice that initiating the traffic stops, handcuffing Dickson, or searching his vehicle was unconstitutional. The court also found that Dickson's factual allegations were contradicted by body-camera footage.
Fourth Amendment Claims — 2019 Stop
The court held that Spies and Knoche had at least reasonable suspicion to stop Dickson based on his close following of their squad car, which implicates a Minnesota traffic statute prohibiting following another vehicle more closely than is reasonable and prudent. Dickson's own statement during the stop — acknowledging that the squad car was going slowly and he was trying to reach Walgreens before closing — confirmed his conduct. Officers also had reasonable suspicion regarding allegedly illegal window tint. The subsequent search of Dickson's vehicle and brief handcuffing were found reasonable given Dickson's noncompliance and the officers' objectively reasonable safety concern. The Fourth Amendment claim failed.
First Amendment Retaliation Claim — 2019 Stop
To survive qualified immunity on a First Amendment retaliatory-arrest claim, a plaintiff must show that officers lacked arguable reasonable suspicion to stop him. Because the court found that Spies and Knoche had at least reasonable suspicion to initiate the 2019 stop based on the traffic violation, the retaliation claim failed.
Fourth Amendment Claims — 2020 Stop
Wong and Majeski had probable cause to initiate the 2020 stop based on Dickson's non-functioning taillights, which violate Minnesota law requiring all signal and stop lamps to be maintained in working condition. Dickson later admitted his brake lights were out. Once stopped, Dickson admitted he had no insurance — an independent violation of Minnesota law that subjected him to arrest — justifying the pat-down search. The court found that the use of handcuffs and the brief force used to place Dickson in the squad car were minimal (described in the opinion as "de minimis") and lawful incident to a lawful seizure. The vehicle search was justified by Dickson's uncertainty about the location of a possible knife and Majeski's belief that Dickson admitted to possessing marijuana. The Minneapolis officers who arrived mid-stop were entitled to rely on the information conveyed in Wong's call for assistance. The Fourth Amendment claims failed.
First Amendment Retaliation Claim — 2020 Stop
Because the court found there was probable cause to arrest Dickson based on his lack of insurance, the First Amendment retaliatory-arrest claim related to the 2020 stop also failed under Eighth Circuit precedent.
Civil Conspiracy
To state a civil conspiracy claim under § 1983, a plaintiff must allege that defendants conspired to deprive him of constitutional rights, that at least one conspirator took an overt act in furtherance of the conspiracy, and that the overt act caused injury. Because the court found no plausible constitutional violation and no plausibly pled overt act in furtherance of any conspiracy, the conspiracy claim failed as a matter of law.
Monell Claim
A Monell claim holds a municipality liable for unconstitutional policies or practices. Because the court found no underlying constitutional violation by any individual officer, there was no basis for municipal liability, and the Monell claim failed.
Disposition
The court granted Hennepin County's Motion to Dismiss (Docket No. 40) and the City of Minneapolis's Motion for Judgment on the Pleadings (Docket No. 50). The entire case was dismissed with prejudice.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.