UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Jared Goyette,
On behalf of himself and other similarly
situated individuals,
Plaintiff,
Court File No. _______________
v.
City of Minneapolis; Minneapolis Chief
of Police Medaria Arradondo in his
individual and official capacity;
Minneapolis Police Lieutenant Robert
Kroll, in his individual and official
capacity; Minnesota Department of
Public Safety Commissioner John
Harrington, in his individual and official
capacity, Minnesota State Patrol Colonel
Matthew Langer, in his individual and
official capacity; and John Does 1-2, in
their individual and official capacities.
Defendants.
CLASS ACTION COMPLAINT AND
DEMAND FOR A JURY TRIAL
For his Complaint, Plaintiff states and alleges as follows:
INTRODUCTION
The press is under assault in our City.
Over the past week, the Minneapolis Police and the Minnesota State Patrol have
tear-gassed, pepper-sprayed, shot in the face with rubber bullets, arrested without cause,
and threatened journalists at gunpoint, all after these journalists identified themselves and
were otherwise clearly engaged in their reporting duties. These are not isolated incidents.
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The past week has been marked by an extraordinary escalation of unlawful force
deliberately targeting reporters.
The ostensible leaders of our law enforcement agencies have been unable to curb
this unlawful violence. Governor Walz and others have repeatedly issued statements
apologizing for the violence against reporters and the unlawful arrests. But these
statements, and whatever behind-the-scenes actions have accompanied them, have proven
toothless.
This pattern and practice of conduct by law enforcement tramples on the
Constitution. It violates the sacrosanct right to freedom of speech and freedom of the press
that form the linchpin of a free society. It constitutes a pattern of unreasonable force and
unlawful seizures under the Fourth Amendment. And it deprives liberty without a
modicum of due process protected by the Fourteenth Amendment.
Plaintiff brings this action and asks the Court to restrain Defendants from further
violence and unconstitutional conduct.
PARTIES
1. Plaintiff Jared Goyette is a Minnesota resident who lives in the city of
Minneapolis. Plaintiff is a freelance journalist who works for national and international
news publications.
2. Defendant City of Minneapolis is a municipality incorporated in the State of
Minnesota.
3. Defendant Medaria Arradondo is the Minneapolis Chief of Police and a
Minnesota resident.
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4. Defendant Robert Kroll is a Lieutenant in the Minneapolis Police
Department, the president of the Minneapolis Police Federation, and a Minnesota resident.
5. Defendant John Harrington is the Minnesota Commissioner of Public Safety
with supervisory responsibility over Colonel Matthew Langer and the Minnesota State
Patrol. Commissioner Harrington is a Minnesota resident.
6. Defendant Colonel Matthew Langer commands the Minnesota State Patrol.
Colonel Langer is a Minnesota resident.
7. Defendants John Does are unidentified individuals who committed the acts
and omissions set forth below as agents of Defendants City of Minneapolis and Minnesota
State Patrol.
JURISDICTION
8. Plaintiff’s claims arise under 42 U.S.C. § 1983, the Fourteenth Amendment
to the United States Constitutions, and the First and Fourth Amendments, as incorporated
against the States, their agencies, and their municipal divisions through the Fourteenth
Amendment.
9. Jurisdiction is proper in this Court according to 28 U.S.C. § 1331 because
Plaintiff’s claims arise under the United States Constitution and federal law.
BACKGROUND
A. GEORGE FLOYD’S MURDER AND THE ENSUING UNREST.
10. On Monday May 25, 2020, George Floyd, a citizen of Minneapolis, was
murdered by an officer of the Minneapolis Police Department (“MPD”). The events of
Floyd’s arrest and murder were captured on video by multiple bystanders as well as
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individual officers’ body cameras. The videos depicted Mr. Floyd pinned on the street,
face down and increasingly unresponsive, while MPD Officer Derek Chauvin knelt on Mr.
Floyd’s upper back and neck, two officers held him down, and another stood by. All four
officers were soon fired by the City. Derek Chauvin has been charged with third-degree
murder and manslaughter.
11. The videos were widely and rapidly disseminated around the world via social
media and news media platforms. Mr. Floyd’s murder became international breaking
news.
12. Over the next five days and nights, thousands of people gathered across
Minneapolis to protest and mourn Mr. Floyd’s murder. Some of the protests grew in
intensity, and isolated bad actors used the protests to engage in the looting and burning of
hundreds of buildings in Minneapolis and Saint Paul.
13. The public unrest became international breaking news. Numerous members
of the news media arrived to cover the demonstrations and unrest and the government
response.
14. Many confrontations occurred during this period between the MPD and State
Patrol, and groups of demonstrators in which law enforcement, without any forewarning,
deployed less-lethal ballistics and chemical irritants against the demonstrators.
15. It is abnormal in situations of public unrest for law enforcement to engage in
potentially injurious riot control tactics without issuing clear warnings and orders to
disperse.
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16. In addition to confronting civilian demonstrators, the MPD and State Patrol
also aggressively confronted members of the news media providing on-the-scene coverage.
Numerous journalists reported injuries sustained as a result of law enforcement’s
unforewarned, indiscriminate use of riot control tactics against clearly identifiable
members of the news media. In one high-profile incident, CNN correspondent Omar
Jimenez was arrested on national television despite asking the State Patrol to “put us back
where you want us, we are getting out of your way.”
1
Mr. Jimenez was only released after
a personal phone call from CNN president Jeff Zucker to Minnesota Governor Tim Walz.
2
17. Governor Walz acknowledged that arresting members of the news media
providing coverage of breaking news stories was improper and said that “there is absolutely
no reason something like this should happen . . . . In a situation like this, even if you’re
clearing an area, we have got to ensure that there is a safe spot for journalism to tell this
story. The issue here is trust, the community that’s down there that’s terrorized by this, if
they see a reporter being arrested, their assumption is something is going to happen that
they don’t want to be seen so that is unacceptable.”
3
18. Despite Governor Walz’s assurances that the role of the media would be
fostered and respected, the MPD, State Patrol, and other law enforcement authorities
continued to target and intimidate members of the news media in a concerted effort to chill
protected First Amendment activity.
1
https://apnews.com/eadfe65c7ce593d04c0aef7eb0276e22.
2
https://www.startribune.com/cnn-reporter-arrested-on-live-tv-let-go-after-gov-tim-walz-
intervened/570860202/
3
https://www.cnn.com/2020/05/29/politics/tim-walz-minnesota-cnn-arrest/index.html
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 5 of 42
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B. CURFEWS ESTABLISHED BY EXECUTIVE ORDER.
19. Due to widespread threat to personal safety and property, Governor Walz
mobilized the Minnesota National Guard. As a result of this order, Defendants all began to
conduct planning and operations in concert as one cohesive law enforcement agency.
20. Governor Walz also issued an executive order establishing a curfew,
effective from 8:00 p.m. to 6:00 a.m. on Friday, May 29 and Saturday, May 30.
4
The
Governor re-issued the curfew order for Sunday, May 31. (“Curfew Orders”).
5
The Curfew
Orders apply to “all public places within the City of Minneapolis and the City of Saint
Paul[.]”
21. The Curfew Orders mandate that “[d]uring the curfew, all persons must not
travel on any public street or in any public place.”
22. The Curfew Orders contain exceptions to the travel prohibition, however:
“All law enforcement, fire, medical personnel, and members of the news media . . . are
exempt from the curfew. Individuals traveling directly to and from work, seeking
emergency care, fleeing dangerous circumstances, or experiencing homelessness are also
exempt.”
23. The City of Minneapolis implemented a similar curfew order that exempted
members of the news media.
4
Minn. Exec. Order No. 20-65 (May 29, 2020),
https://mn.gov/governor/assets/EO%2020-65%20Final_tcm1055-434123.pdf.
5
Minn. Exec. Order No. 20 68 (May 31, 2020),
https://mn.gov/governor/assets/EO%2020-68%20Final_tcm1055-434218.pdf.
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24. Upon information and belief, there is no system in place for members of the
media to apply for or obtain official credentials from the Minneapolis Police Department
or the State Patrol.
C. DEFENDANTS’ UNCONSTITUTIONAL ACTIONS AGAINST THE
PRESS COVERING THE RECENT PROTESTS.
25. Even though members of the news media were expressly exempt from the
Curfew Orders, Defendants ignored the exemption. Even when members of the news
media clearly identified themselves, Defendants continued to target and intimidate the
press by threatening, spraying chemical irritants, and firing less-lethal ballistics designed
for riot control directly at members of the media. Defendants further interfered with the
news media’s right to cover public events by refusing access to areas where events were
unfolding and creating obstacles to reporters’ movement about the city. These incidents
constitute flagrant infringements on the constitutional rights of individual reporters, as well
as the public’s interest in the dissemination of accurate information and accountability of
government for its actions. The unlawful actions of the Defendants include but are not
limited to the following incidents.
ARRESTS
26. On May 30, a Minnesota State Patrol trooper forced WCCO videographer
Tom Aviles to the ground and arrested him even though Aviles had identified himself as a
member of the press and was carrying a large video camera.
6
Aviles’s producer Joan
6
https://www.startribune.com/wcco-cameraman-arrested-on-video-while-covering-
unrest-in-minnesota/570902742/
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Gilbertson was with him at the time. She also identified herself as a journalist. A State
Patrol trooper told her, “You’ve been warned, or the same thing will happen to you. Or
you’re next.” Aviles spent two hours in custody. Earlier police had shot Aviles with a
less-lethal projectile even though he was filming them with a large video camera at the
time and was clearly identifiable as a member of the press.
7
27. On May 29, a Minnesota State Patrol trooper handcuffed and arrested CNN
reporter Omar Jimenez and his news crew during a live broadcast. It was daytime, there
were no protesters around, and Jimenez asked the State Patrol where they should position
themselves prior to being arrested, stating, “Put us back where you want us, we are getting
out of your way, just let us know.” When Jimenez further pressed the trooper who arrested
him why he was being arrested, the trooper stated, “Look, I don’t know man, I’m just
following orders.” The crew was readily identifiable as a CNN news crew and identified
themselves as such repeatedly before being handcuffed and arrested.
8
The crew was
detained for an hour.
28. On May 30, European Press Photo Agency photojournalist Tannen Maury
and professional photojournalist Craig Lassig were arrested and charged with curfew
violations despite having identified themselves as members of the press.
9
29. While covering the protests on May 31, Star Tribune reporter Liz Sawyer
identified herself as a journalist to Minneapolis Police. She was told, “we don’t care, we’ll
7
https://twitter.com/WCCO/status/1266920992946954241
8
https://www.nytimes.com/2020/05/29/business/media/cnn-reporter-arrested-omar-
jimenez.html
9
https://twitter.com/MJKauz/status/1267273646621499392
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 8 of 42
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arrest you.”
10
Earlier that evening, Sawyer was standing with Star Tribune reporter Chao
Xiong, two Kurdish journalists, and one Japanese journalist. Minneapolis Police officers
told them to go home. When the group identified themselves as press and showed their
credentials, an officer said, “Your cards are bullshit.”
11
30. On May 30, NBC reporter Simon Moya-Smith was arrested by the
Minneapolis Police despite identifying himself multiple times as a reporter and displaying
his press badge for the arresting officer.
12
Moya-Smith was pepper sprayed during the
arrest.
31. Early on the morning of May 31, an Australian television news team led by
Tim Arvier was detained and searched by Minneapolis Police after identifying themselves
as members of the press. During this detention the news team’s cameraman was
handcuffed despite clearly being a member of the news media and being no threat to
anyone.
13
USE OF PHYSICAL FORCE
32. On May 29, veteran AP photojournalist John Minchillo was shot with a less-
lethal projectile. He stated in a social media post, “No distinctions were made . . . when I
and my colleagues were hit by officers. Last night was full force in a wide spread. This is
a protocol that I’ve not seen elsewhere.”
14
10
https://twitter.com/ByLizSawyer/status/1266984068765409280
11
https://twitter.com/ChaoStrib/status/1266959110265856000
12
https://twitter.com/SimonMoyaSmith/status/1267054164774916096
13
https://twitter.com/TimArvier9/status/1266969637817909250
14
https://twitter.com/johnminchillo/status/1267116569223725059
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 9 of 42
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33. On May 30, Minnesota State Patrol troopers backed Los Angeles Times
reporter Molly Hennessy-Fiske and photographer Carolyn Cole against a wall and fired
tear gas and less-lethal projectiles at them. The two were wearing their press credentials,
and Cole wore a flak jacket labeled “Press.” Hennessy-Fiske shouted “Press” at the officers
and waved her notebook at them before they fired.
15
They asked the officers where to go
but received no answer. When they tried to flee, the officers chased them and fired more
less-lethal projectiles at them. Hennessy-Fiske was bleeding and saw another reporter next
to her stunned and bleeding from the face. Hennessy-Fiske stated she has covered protests
in Ferguson, Baton Rouge, Dallas and Los Angeles, and covered the military in Iraq and
Afghanistan, but had never been fired on until her reporting in Minnesota.
16
34. On May 30, Star Tribune reporters Ryan Faircloth and Chao Xiong were
trying to leave the protests in Faircloth’s car. They mistakenly turned down a street that
was blocked off at the end. Before they could turn around, the State Patrol fired less-lethal
projectiles at the car, without warning. Later, when Faircloth was driving alone out of the
area, officers again fired less-lethal rounds at Faircloth’s vehicle, injuring Faircloth and
blowing out the windows of the car.
17
35. On May 30, freelance journalist Linda Tirado was photographing the protests
when police or troopers shot her in the face with a less-lethal projectile. She is now
permanently blind in her left eye.
18
15
https://twitter.com/mollyhf/status/1266979120686260224?s=20
16
https://www.latimes.com/world-nation/story/2020-05-30/la-reporter-tear-gas-police
17
https://twitter.com/RyanFaircloth/status/1266954131324928003
18
https://www.nytimes.com/2020/05/30/us/minneapolis-protests-press.html
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 10 of 42
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36. On May 30 Minneapolis Police fired less-lethal projectiles at CBS reporter
Michael George and his news crew, hitting sound engineer John Marschitz and severely
bruising his arm.
19
The crew was not standing within 500 feet of any protesters at the time
and had their credentials displayed and their cameras out.
20
37. On May 30, police or troopers fired less-lethal projectiles at an MSNBC news
crew, including reporter Ali Velshi, hitting Velshi in the leg.
21
After this incident, Velshi
and another TV crew were confronted by police in a nearly deserted parking lot. The group
informed the police that they were news media. The officers responded, “we don’t care,”
and began firing on the group with less-lethal projectiles.
38. On May 30, Reuters TV cameraman Julio-Cesar Chavez was filming police
when one aimed a less-lethal projectile gun at directly at Chavez. Later that evening, in a
separate incident, police fired directly at Chavez and his crew with less-lethal projectiles.
22
Chavez was hit in the back of his neck, under his left eye, and in his arm. A member of
his crew was also hit. They were clearly identifiable as press at the time.
23
19
https://twitter.com/MikeGeorgeCBS/status/1266919447970942986
20
https://twitter.com/MikeGeorgeCBS/status/1266916104951214080
21
https://www.washingtonpost.com/lifestyle/media/journalists-at-several-protests-were-
injured-arrested-by-police-while-trying-to-cover-the-story/2020/05/31/bfbc322a-a342-
11ea-b619-3f9133bbb482_story.html
22
https://www.reuters.com/article/us-minneapolis-police-protest-update/reuters-camera-
crew-hit-by-rubber-bullets-as-more-journalists-attacked-at-us-protests-idUSKBN237050
23
https://www.washingtonpost.com/lifestyle/media/journalists-at-several-protests-were-
injured-arrested-by-police-while-trying-to-cover-the-story/2020/05/31/bfbc322a-a342-
11ea-b619-3f9133bbb482_story.html
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39. On May 30, photojournalist Lucas Jackson was pepper sprayed in the face
and also shot in the back with a less-lethal projectile.
24
Lucas stated in a social media post,
“It’s not that we were being shot because we were between cops and protesters. It’s that
we were shot at if we were anywhere in line of sight. I’ve been hit because I was in the
wrong place before. I’ve never been aimed at so deliberately so many times when I was
avoiding it.”
25
40. On May 30, CBC senior news correspondent Susan Ormiston was hit in the
shoulder by a less-lethal projectile and in the back by a tear gas canister. At the time she
was shot, she was in a parking lot that had been cleared of protesters, and she and her crew
were clearly identifiable as media.
26
41. On May 30, Minneapolis Police fired a flash bang grenade directly into an
MSNBC news crew led by reporter Morgan Chesky, despite the fact that Chesky was live
on television and he and his crew were clearly identifiable as news media.
27
42. Among the munitions used against journalists were the 40mm Skat Shell
(which is a delivery device for chemical agents) and the Direct Impact LE 40mm Extended
Range Round.
43. According to Defense Technology, Inc., the manufacturer of the 40mm Skat
Shell: “The 40mm Skat Shell® is designed for outdoor use and has fire producing
24
https://twitter.com/Lucas_Jackson_/status/1266666583012892672
25
https://twitter.com/Lucas_Jackson_/status/1267114291532046338
26
https://twitter.com/mcquillanator/status/1266915485741993996
27
https://twitter.com/AndyRowell/status/1266946038373347328
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 12 of 42
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capability. It is not intended for barricade penetration. Do NOT fire directly at personnel,
as serious injury or death may result.”
28
44. Defense Technology, Inc., also manufactures the Direct Impact 40mm
Extended Range Round. It states: “The Direct Impact® Extended Range Round should
only be used at ranges beyond 10 meters, targeting the subject’s lower torso or extremities.
Impacts closer than 10 meters or targeting the subject’s head, neck, or upper torso can result
in serious injury or death.”
29
45. On information and belief, MPD and the Minnesota State Patrol fired both
the Skat Shell and the Direct Impact Round at journalists in a manner contrary to the
manufacturer’s warnings and likely to cause injury, and in fact resulting in injury in
numerous instances.
USE OF CHEMICAL AGENTS
46. On May 30, Minneapolis Police aimed a rifle directly at Vice magazine
journalist Michael Adams while Adams was covering the protests. At the time, Adams
and other journalists clustered near him were holding up their press passes. Shortly
thereafter, a Minneapolis Police officer approached Adams with a weapon pointed directly
at him and threw him to the ground. He was displaying his press pass and shouting “press.”
The officer responded, “I don’t care.” Adams was on his knees, alone, clearly not a threat,
28
https://www.defense-technology.com/on/demandware.static/-/Sites-DefenseTech-
Library/default/dw66a06e0e/product-pdfs/less-lethal/40mm_Skat_Shell.pdf
29
https://www.defense-technology.com/on/demandware.static/-/Sites-DefenseTech-
Library/default/dw7cc762e7/product-
pdfs/40mm%20Direct%20Impact%20LE%20Extended%20Range%20Round.pdf
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 13 of 42
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and was surrounded by more than a dozen officers.
30
The officer who threw Adams down
told him not to move. Adams complied. Another officer slowly walked by Adams. When
Adams again said “I’m Press,” and held up his credential, this officer casually pepper
sprayed Adams directly in the face from several inches away, then continued strolling
while Adams writhed on the ground in agony.
31
47. KSTP investigative reporter Ryan Raiche, his photographer, and his
producer, were gathered together with a group of other media members during protests on
the evening of May 30 outside the Fifth Precinct. Most had large cameras, boom mikes,
or visible press credentials. The group was clearly identifiable as media. They were pinned
against a wall together as a police line advanced. Police walked up to the group and
indiscriminately pepper sprayed the entire group.
32
48. On May 28, Star Tribune columnist Jennifer Brooks was standing at a light
rail station on S. 5
th
Street documenting the protests in a group of other media members.
Several Minneapolis Police squad cars drove by unimpeded. As Squad Car 181 passed the
journalists, the driver’s side window rolled down and the driver indiscriminately pepper
sprayed Brooks, other media members, and nearby protesters.
33
49. On May 29, USA Today reporter Tyler Davis was covering the protests in
downtown Minneapolis. Several squad cars pulled up at his location, police got out and
began indiscriminately spraying pepper spray canisters in every direction and telling people
30
https://twitter.com/MichaelAdams317/status/1267203751913422849
31
https://twitter.com/MichaelAdams317/status/1266945268567678976?s=20
32
https://twitter.com/ryanraiche/status/1267021649959845888
33
https://twitter.com/stribrooks/status/1266186985041022976
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 14 of 42
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to move north. Davis was filming two young women being pepper sprayed to his left,
when the officer doing the spraying turned to Davis. Davis identified himself as a member
of the media, and the officer “laid on the trigger for a few seconds” spraying Davis directly
in the face.
34
50. On May 30, Star Tribune photographer Anthony Souffle was tear gassed by
police or troopers.
35
USE OF THREATENING LANGUAGE AND GESTURES
51. On May 31, Minneapolis Police officers in a truck pulled up to a group of
reporters, including Star Tribune reporter Andrew Mannix, pointed a “large gun” at the
group and shouted, “do you know what curfew is?” After notifying the officers that they
were journalists and walking to their cars, the police ordered them to leave the area.
36
52. On May 30, Star Tribune reporter Chris Serres was twice ordered at gunpoint
by Minneapolis Police to “hit the ground,” and warned that “if [he] moved an inch [he’d]
be shot,” despite prominently displaying his Star Tribune press badge for the police.
37
He
had already been tear gassed and shot in the groin with a less-lethal projectile earlier in the
day.
53. Maggie Koerth, a reporter for the website FiveThirtyEight was covering the
protests from a sidewalk on May 30. A Minneapolis Police officer drew a weapon on
34
https://www.usatoday.com/story/opinion/2020/05/29/george-floyd-protests-leave-usa-
today-reporter-hit-chemical-spray/5282374002/
35
https://twitter.com/AnthonySouffle/status/1267122936105893892
36
https://twitter.com/AndrewMannix/status/1266968276481052672?s=20
37
https://twitter.com/ChrisSerres/status/1267098060938776581
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 15 of 42
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Koerth and Plaintiff Jared Goyette. Koerth and Goyette said “press, press” and held up
their press badges. The officer continued to point the gun at Koerth and told Koerth to
“Shut up.”
38
54. On May 30, MPR reporter Madeleine Baran was covering the protests with
American Public Media journalist Samara Freemark. A Minneapolis police officer pointed
a weapon at their heads. When they identified themselves as press, the officer did not lower
his weapon, so they ran for cover and ended their reporting for the night.
39
55. Graphic images taken during the protests show the trauma wrought by
Defendants’ unconstitutional actions.
38
https://www.nytimes.com/2020/06/01/business/media/reporters-protests-george-
floyd.html?smid=tw-share
39
https://twitter.com/madeleinebaran/status/1266610933071138816
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 16 of 42
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56. Below is a photograph of NBC video and photojournalist Ed Ou, who was
pepper sprayed and shot with a less-lethal projectile:
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18
57. Below is a photograph of freelance journalist Linda Tirado. The Minneapolis
Police permanently blinded Ms. Tirado in her left eye with a less-lethal projectile.
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 18 of 42
19
58. Below is a photograph of KSTP reporter Ryan Raiche after being pepper
sprayed despite identifying himself as a member of the press:
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20
59. Below is a photo that Reuters cameraman Julio-Cesar Chavez took of police
taking direct aim at him despite his being clearly identifiable as a member of the press:
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21
60. Below is an image of the arrest of Omar Jimenez and his news crew:
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22
61. Below are images published by Molly Hennesy-Fiske of the kinds of less-
lethal projectiles that law enforcement fired at journalists.
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23
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 23 of 42
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62. Below is a photograph of the injuries Molly Hennessy-Fiske suffered after
law enforcement shot her with less-lethal projectiles:
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D. NAMED-PLAINTIFF JARED GOYETTE.
63. Plaintiff Jared Goyette is a freelance journalist. At all times relevant to this
Complaint, Plaintiff was working on assignment as a contract journalist with a national
publication.
64. At around 5:00 p.m. on May 27, 2020, Plaintiff was observing and
documenting the demonstrations near the MPD’s Third Precinct, located at the intersection
of Lake Street and Minnehaha Avenue. MPD officers protecting the Third Precinct were
firing ballistic rounds, marker rounds, and tear gas intermittently and without warning or
orders for dispersal.
65. Plaintiff was clearly a member of the news media. He carried a camera and
a monopod (a single, long leg used to stand a camera on for stability), notepad, and mobile
phone. These items would have been visible to the MPD stationed on top of and outside
the Third Precinct.
66. Plaintiff was standing 30 to 50 yards from the Third Precinct when he saw a
young man who appeared to be severely injured. Plaintiff went towards the man to
document the incident.
67. Plaintiff was shot in the face with less-lethal ballistic ammunition shortly
after other bystanders took the injured young man from the scene. MPD provided no
warning for this use of force. Plaintiff was standing alone and there was no one else within
several feet of Plaintiff.
68. Plaintiff suffered immediate physical injury to his nose and eye and, as a
result, had to leave the scene and cease journalistic activities for the evening. After
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 25 of 42
26
receiving medical treatment, Plaintiff ventured back to the demonstrations to continue to
provide press coverage.
69. In the days after his injury, Plaintiff experienced several instances of
intimidating and obstructive behavior from Defendants. For example, he was told to “Shut
up” by an officer after identifying himself as press. In another instance, an officer passing
by Plaintiff and another female reporter shouted at them, “I want to fucking peg you.”
70. Plaintiff intends to continue documenting and reporting on additional
protests and other First Amendment protected expression, and the police response to these
protests.
MUNICIPAL ALLEGATIONS
71. The City of Minneapolis, Minneapolis Chief of Police Medaria Arradondo,
Minneapolis Police Lieutenant Robert Kroll, Minnesota Department of Public Safety
Commissioner John Harrington, and Minnesota State Patrol Colonel Matthew Langer, in
their official capacities (the “State and Municipal Defendants”) each have policies and
customs of violating the constitutional rights of members of the press.
72. The State and Municipal Defendants each have a custom or policy of
deploying chemical agents and injurious, less-lethal ballistics against members of the news
media. For example, both chemical agents and less-lethal ballistics were fired at the news
media from the roof of the Minneapolis Police Department’s Third Precinct Police Station
by officers detailed to the roof during the protest. Photographs of the injuries intentionally
inflicted on the news media by these shots fired from the Third Precinct roof were
published in the international press.
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73. The State and Municipal Defendants each have a custom or policy of failing
to provide warnings and/or dispersal orders before using chemical agents and injurious,
less-lethal ballistics against protesters and members of the news media.
74. The State and Municipal Defendants each have a custom or policy of
arresting or detaining news media lawfully reporting on protests and other First
Amendment expressive activity.
75. After the barrage of international criticism arising out of its illegal detention
of Jimenez and his crew, the State Patrol issued the following statement: “In the course of
clearing the streets and restoring order at Lake Street and Snelling Avenue, four people
were arrested by State Patrol troopers, including three members of a CNN crew. The three
were released once they were confirmed to be members of the media.” Of course, it was
obvious from the outset that these individuals were members of the media, no threat, and
sought to accommodate the State Patrol in its mission. Arresting them had nothing to do
with “restoring order” and everything to do with retaliating against and intimidating the
press.
76. On information and belief, the MPD has not investigated, disciplined, or
suspended any officer involved in any of the unlawful conduct described in this Complaint.
77. The State and Municipal Defendants have a history of unconstitutional
actions against journalists.
78. For example, in 2002, the Minnesota Daily (the University of Minnesota
student newspaper) filed a complaint with the MPD’s Internal Affairs Division related to
officer actions against student journalists during a riot following a University of Minnesota
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Hockey championship victory. According to written statements in the complaint, a
photographer was pushed to the ground from behind and kicked in the back. When a
reporter went to help the photographer, she was sprayed directly in the face with chemical
irritant. Two other photographers were sprayed in the face with chemical irritant and hit
repeatedly with a riot stick. Two photographers had press passes displayed in the middle
of their chests, and the others told police officers they were members of the press, according
to the complaint.
40
On information and belief, none of the officers involved in this conduct
were disciplined pursuant to this investigation.
41
79. In 2008, Amy Goodman, host of “Democracy Now!”, and her crew were
arrested during the Republican National Convention in St. Paul, despite posing no threat
and complying with police orders.
42
Defendant John Harrington, then St. Paul Police
Chief, brushed off the First Amendment concerns.
80. In 2017, the Minnesota State Patrol arrested City Pages journalist Susan Du
and Minneapolis Daily City Editor David Clarey during the protests following the Philando
Castile killing. Du’s phone, camera, keys, notes, and laptop were seized. The State Patrol
detained Du and Clarey for nine hours, even though they had attempted to comply with
40
https://archive.nytimes.com/www.nytimes.com/uwire/uwire_JOIN042420022302015.ht
ml
41
https://splc.org/2002/08/students-await-word-on-probe-into-police/
42
https://www.minnpost.com/politics-policy/2008/09/amy-goodmans-arrest-when-
journalists-are-story/
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officers’ directions to disperse. On information and belief, no troopers were investigated
or disciplined for these unlawful arrests.
81. The State and Municipal Defendants have been operating in close concert
and in coordination during the protests.
82. Defendants have a history of deficient or non-existent training with respect
to the Constitution in general and Plaintiff’s First Amendment rights in particular.
83. For example, the Minneapolis Police Policy and Procedure Manual Section
6-200 provides:
MPD employees shall not unnecessarily obstruct news media
personnel from performing their duties at emergency scenes.
However, news media will not be allowed to cross police lines,
which are set up to protect a crime scene. Members of the
media must follow all municipal, state, and federal statutes.
Media can be restricted from an area where their presence can
jeopardize police operations. Only the ranking on-scene officer
may grant news media representatives access to any area
closed because of investigation or health and safety hazards.
The manual provides no other instruction or guidance on how to identify the media or
ensure their First Amendment rights are respected. It does not discuss how to safeguard
press freedoms at protests, and Section 6-200 does not appear to have been updated since
2008.
84. The State and Municipal Defendants’ failure to supervise and train their
employees and agents with respect to First Amendment protected activity amounts to a
deliberate indifference to the rights of the Class Members.
85. Defendant Kroll is both a Lieutenant in the Minneapolis Police Department
and also the president of the Minneapolis Police Federation, the union that represents
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Minneapolis police officers. Kroll’s supervisory role is significantly amplified by his
position as Federation president. Kroll acts as an unofficial policymaker within the MPD.
The MPD’s customs and practices derive not just from the command structure within the
department, but also informally from Kroll, who acts as a de facto policy maker for a cadre
of officers in the department. Kroll actively sows discord between rank-and-file officers
and the command structure as a means of further amplifying his policy role and exercising
an outsize influence over police culture. What Kroll casts as his “opinions” as union
president have the practical effect of serving as policy guidance for officers, which
aggravates the training and supervision failures described above.
86. On June 2, 2020, Kroll released a statement to Federation members that
underscores his role as de facto policymaker and his failure to supervise with respect to the
particular First Amendment issues described in this Complaint.
43
87. Kroll’s June 2 statement seeks to drive a wedge between rank-and-file
officers and MPD leadership:
“No one with the exception of [Kroll and the Federation board]
is willing to recognize and acknowledge the extreme bravery
you have displayed throughout this riot.”
“What has been very evident throughout this process is you
have lacked support from the top.”
“I’ve noted in press conferences from our mayor, our governor,
and beyond, how they refuse to acknowledge the work of MPD
and continually shift blame to it. It is despicable behavior.
How our command staff can tolerate it and live with
themselves I do not know.”
43
https://twitter.com/ChiefHarteau/status/1267460683408564225/photo/1
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“Your federation board will not remain silent. It’s important
for us to get order restored and safety resumed. We do have a
lot to say about failed leadership when the time is right. We’ve
been formulating plans for that.”
88. Kroll’s statement also flags both his outsized supervisory role and his failure
to supervise. In it, he speaks of himself as though he, and not Chief Arradondo, leads the
department, and he ratifies the rampant unconstitutional conduct detailed below:
“Although I have not been visibly present, I am closely
monitoring what is occurring. I commend you for the excellent
police work you are doing . . .”
“I’ve had numerous conversations with politicians at the state
level. I gave a detailed plan of action including a range of 2000
to 3000 National Guard, their deployment allocations
throughout our city and St. Paul, in a phone meeting with
Senate majority leader Paul Gazelka.”
“I’ve worked with other police leaders from New York to Las
Vegas to push our messaging on a national level.”
89. Kroll’s statement scapegoats the “liberal media,” accusing the press of
somehow preventing him from being more vocal, and explicitly tying media coverage to
danger to the rank-and-file police officers and to Kroll himself, statements which constitute
incitement against the press given the current climate of unrest:
“I’ve been a visible target from the groups conducting this riot,
politicians on the left allowing it and encouraging it, and liberal
media. My visibility during this time would only increase your
danger. I’ve received countless death threats throughout this.”
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90. Former Minneapolis Police Chief Janee Harteau responded to the Kroll
statement by stating: “A disgrace to the badge! This is the battle that myself and others
have been fighting against. Bob Kroll turn in your badge!”
44
91. Notably, Kroll has a long history of racist and inflammatory statements and
conduct, from calling Attorney General (then Congressman) Keith Ellison a “terrorist” for
calling for police reform, to his membership the City Heat motorcycle club, an organization
called out by the Anti-Defamation League for displaying white supremacist symbols. Kroll
was even sued in a section 1983 action by current Chief Arradondo and several other
plaintiffs.
92. The State and Municipal Defendants are fully cognizant of the constitutional
rights they are failing to protect.
CLASS ALLEGATIONS
93. Under Rules 23(a) and 23(b)(1) and (2) of the Federal Rules of Civil
Procedure, Plaintiffs bring this action for prospective relief on behalf of themselves and
other similarly situated people who, as members of the news media
45
, will in the future
observe and record protest activity and the conduct of law enforcement officers on duty in
public places within the cities of Minneapolis and Saint Paul in traditional or designated
public fora (the “Plaintiff Class”). The Plaintiff Class is defined as:
All members of the news media, as the term is used in Emergency
Executive Order 20-69, who intend to engage in news gathering or reporting
44
https://twitter.com/ChiefHarteau/status/1267460683408564225
45
The term “members of the news media” is used in the Curfew Orders as well as the
May 29, 2020 City of Minneapolis Emergency Regulation No. 2020-2-1.
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activities in Minnesota related to the protest activities that followed the death
of George Floyd and the law enforcement response to those protests.
94. The Plaintiff Class is so numerous that joinder of all the members would be
impracticable. Hundreds of members of the news media are in Minneapolis and Saint Paul
to cover the protests that followed Mr. Floyd’s murder and the aftermath.
95. As a result of the State and Municipal Defendants’ customs and policies of
arresting members of the news media, targeting them with less-lethal projectiles and
chemical irritants without constitutionally adequate justification or warning, denying them
freedom of movement to observe and record public demonstrations and law enforcement
officers on duty, and intimidation by threats of violence, the Plaintiff Class have been and
will continue to be deprived of their constitutional rights under the First, Fourth, and
Fourteenth Amendments.
96. Plaintiff’s claims for prospective relief are typical of the members of the
Plaintiff Class because Protests are ongoing and Plaintiff and the Plaintiff Class members
have a reasonable fear that Defendants will continue to carry out their unconstitutional
customs or policies of deploying less-lethal projectiles and chemical irritants without
constitutionally adequate warning, denying them freedom of movement to observe and
record public demonstrations and law enforcement officers on duty, and intimidation by
threats of violence.
97. Plaintiff will fairly and adequately protect the interests the interests of the
Plaintiff Class. Plaintiff has no conflicts involving other class members or Defendants.
Plaintiff understands his role as a class representative and his duties to the class in this
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litigation. Plaintiff is represented by competent and skilled counsel whose interests are
fully aligned with the interests of the class.
98. Questions of law or fact are common to the class. These legal and factual
questions include but are not limited to:
a. Do arrests and targeting of journalists through a series of common
methods violate the First, Fourth, and Fourteenth Amendments?
b. Are the State and Municipal Defendants liable for implementing an
unlawful policy or custom as set forth under principles of municipal
liability?
c. Have the State and Municipal Defendants manifested a failure to
properly train and supervise their agents and officers?
d. Have the State and Municipal Defendants exhibited a deliberate
indifference to the unconstitutional conduct alleged herein?
99. Maintaining individual actions would create a risk of “inconsistent or varying
adjudications with respect to individual class members that would establish incompatible
standards of conduct for the party opposing the class.” Fed. R. Civ. P. 23(b)(1)(A). Multiple
courts issuing multiple injunctions governing the engagement and use-of-force standards
for law enforcement would be entirely untenable. Doing so would only contribute to a state
of uncertainty and confusion that allows the constitutional violations described in the
complaint to continue.
100. This case involves “adjudications with respect to individual class members
that, as a practical matter, would be dispositive of the interests of the other members not
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parties to the individual adjudications.” Fed. R. Civ. P. 23(b)(1)(A). A ruling with respect
to a single Plaintiff in this case would arguably be strong stare decisis—if not necessarily
res judicata—with respect to other putative class members and members of the law
enforcement community. There is no benefit to allowing the overwhelmingly common
issues in this case to be litigated individually. The interests of both class members and
defendants requires classwide treatment.
101. Finally, “the party opposing the class has acted or refused to act on grounds
that apply generally to the class, so that final injunctive relief or corresponding declaratory
relief is appropriate respecting the class as a whole[.]” Fed. R. Civ. P. 23(b)(1)(A). There
is no allegation that Plaintiff has been targeted because of anything unique to him as an
individual. Rather, he has been repeatedly targeted because of his membership in a class of
journalists. Plaintiff’s targeting exists only by virtue of a broader pattern and practice of
unconstitutional conduct directed at journalists as a class. Logically, injunctive relief for
the “class as a whole” is the only mechanism available to afford relief in light of conduct
directed specifically to the class.
CAUSES OF ACTION
COUNT I:
First Amendment—Retaliation, 42 U.S.C. § 1983
1. Plaintiff and the Plaintiff Class restate and reallege all previous paragraphs
of this Complaint.
2. Plaintiff and the Plaintiff Class engaged in constitutionally protected acts of
observing and recording events of public interest, including public demonstrations and the
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conduct of law enforcement officers on duty in a public place. Plaintiff and the Plaintiff
Class will continue to do so in the future to cover the events related to the protests and law
enforcement’s response.
3. Defendants retaliated against Plaintiff and the Plaintiff Class for engaging in
constitutionally protected activity. Defendants’ retaliation is part of a pattern or practice of
unconstitutional conduct that is certain to continue absent any relief.
4. Plaintiffs and the Plaintiff Class reasonably fear the continued deployment
of chemical agents without warning, unlawful seizure, and excessive force through the
firing of flash bang grenades, less-lethal projectiles, riot batons, and other means if they
continue to engage in constitutionally protected activity.
5. These acts would chill a reasonable person from continuing to engage in a
constitutionally protected activity. These acts did, in fact, chill Plaintiff and the Plaintiff
Class from continuing to observe and record some events of public interest, including
constitutionally protected demonstrations and the conduct of law enforcement officers on
duty in a public place.
6. It was the State and Municipal Defendants’ custom and policy, as well as
their failure to train and supervise their officers, and issue corrective instructions after
violations were brought to light, that caused the First Amendment retaliation.
7. The State and Municipal Defendants’ failure to supervise and train their
employees and agents with respect to the First Amendment rights of Plaintiff and the
Plaintiff Class, including a failure to investigate and discipline officers for First
CASE 0:20-cv-01302 Document 1 Filed 06/02/20 Page 36 of 42
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Amendment violations, amounts to deliberate indifference to the rights of Plaintiff and the
Plaintiff Class.
8. The pattern of similar constitutional violations against Plaintiff and the
Plaintiff Class that occurred during the Floyd protests demonstrates the deliberate
indifference of the State and Municipal Defendants to the rights of Plaintiff and the Plaintiff
Class.
9. Further, given the multiple constitutional violations documented above, the
need for more supervision or training was so obvious, and the inadequacy of the training
and supervision so likely to result in the violation of constitutional rights, that the State and
Municipal Defendants demonstrated their deliberate indifference to the need for such
training and supervision.
10. Plaintiff Goyette’s First Amendment rights were violated when he was
deliberately targeted and shot with a rubber bullet during the course of his reporting
activities.
11. Plaintiff and the Plaintiff Class reasonably fear further retaliation in the
future if they continue to observe, record, or participate in constitutionally protected
activity.
COUNT II:
Fourth Amendment—Unlawful Seizure and Excessive Force
12. Plaintiff and the Plaintiff Class restate and reallege all previous paragraphs
of this Complaint.
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13. Plaintiff and the Plaintiff Class were seized by Defendants when their
officers intentionally, through the use of force and threat of arrest, chemical agents, and
nonlethal projectiles, terminated their freedom of movement. For example, a newscaster
was prevented from traveling from Saint Paul to Minneapolis;
46
14. Members of the Plaintiff Class were also seized by Defendants when they
were arrested and detained.
15. Defendants committed these acts without forewarning and, as a result,
Defendants’ acts were objectively unreasonable and constituted unlawful seizure and
excessive force.
16. Plaintiff and the Plaintiff Class did not commit a crime, because as members
of the news media, they were specifically exempted from the Curfew Orders and permitted
to cover the protests outside the restricted times.
17. Plaintiff and the Plaintiff class did not pose a threat to any of Defendants’
officers or agents or any other person.
18. It was the State and Municipal Defendants’ custom and policy, as well as
their failure to train and supervise their officers, and issue corrective instructions after
violations were brought to light, that caused the unlawful seizures and excessive use of
force.
19. The State and Municipal Defendants’ failure to supervise and train their
employees and agents with respect to the Fourth Amendment rights of Plaintiff and the
46
https://twitter.com/JohnCroman/status/1266954423147864067?s=20
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Plaintiff Class, including a failure to investigate and discipline officers for Fourth
Amendment violations, amounts to deliberate indifference to the rights of Plaintiff and the
Plaintiff Class.
20. The pattern of similar constitutional violations against Plaintiff and the
Plaintiff Class that occurred during the Floyd protests demonstrates the deliberate
indifference of the State and Municipal Defendants to the rights of Plaintiff and the Plaintiff
Class.
21. Further, given the pattern and practice of constitutional violations
documented above, the need for more supervision or training was so obvious, and the
inadequacy of the training and supervision so likely to result in the violation of
constitutional rights, that the State and Municipal Defendants demonstrated their deliberate
indifference to the need for such training and supervision.
22. Plaintiff Goyette’s Fourth Amendment rights were violated when he was
deliberately targeted and shot with a rubber bullet during the course of his reporting
activities.
23. Plaintiff and the Plaintiff Class reasonably fear further retaliation in the
future in violation of the Fourth Amendment if they continue to observe, record, or
participate in constitutionally protected activity.
COUNT III:
Fourteenth Amendment—Procedural Due Process
24. Plaintiff and the Plaintiff Class restate and reallege all previous paragraphs
of this Complaint.
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25. The Due Process rights of Plaintiff and the Plaintiff Class were violated when
the State and Municipal Defendants, through their officers and agents, arrested members
of the Plaintiff Class without probable cause, and deployed chemical agents and nonlethal
projectiles without providing a warning and opportunity to disperse in a way that a person
of ordinary intelligence could understand and comply with.
26. The State and Municipal Defendants’ failure to supervise and train their
employees and agents with respect to the Due Process rights of Plaintiff and the Plaintiff
Class, including a failure to investigate and discipline officers for Fourteenth Amendment
violations, amounts to deliberate indifference to the rights of Plaintiff and the Plaintiff
Class.
27. The pattern of similar constitutional violations against Plaintiff and the
Plaintiff Class that occurred during the George Floyd protests demonstrates the deliberate
indifference of the State and Municipal Defendants to the rights of Plaintiff and the Plaintiff
Class.
28. Further, given the multiple constitutional violations documented above, the
need for more supervision or training was so obvious, and the inadequacy of the training
and supervision so likely to result in the violation of constitutional rights, that the State and
Municipal Defendants demonstrated their deliberate indifference to the need for such
training and supervision.
29. Plaintiff Goyette’s Fourteenth Amendment rights were violated when he was
deliberately targeted and shot with a rubber bullet during the course of his reporting
activities.
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41
30. Plaintiff and the Plaintiff Class reasonably fear further violation of the right
to due process in the future if they observe, record, or participate in constitutionally
protected activity.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, individually and as a representative of the class defined
herein, prays for relief as follows:
A. A temporary restraining order barring Defendants from engaging in
unconstitutional conduct targeting journalists, as set forth in the proposed
order accompanying Plaintiff’s motion for a temporary restraining order.
B. A preliminary injunction barring Defendants from engaging in
unconstitutional conduct targeting journalists, as set forth in the proposed
order accompanying Plaintiff’s motion for a temporary restraining order.
C. A determination that this action may proceed as a class action under Rule
23(b)(1) or 23(b)(2) of the Federal Rules of Civil Procedure;
D. Designation of Plaintiff as Class Representative and designation of
Plaintiff’s counsel as class counsel;
E. A declaration that Defendants’ conduct violated the First, Fourth, and
Fourteenth Amendments of the U.S. Constitution;
F. A permanent injunction barring Defendants from engaging in
unconstitutional conduct targeting journalists, as set forth in the proposed
order accompanying Plaintiff’s motion for a temporary restraining order;
G. Damages compensating Plaintiff for his injuries, including but not limited
to compensatory, pecuniary, and medical expense damages;
H. An award of pre-judgment interest;
I. An award of attorneys’ fees and costs pursuant to 42 U.S.C. § 1988;
J. An award of such other and further relief as the Court deems equitable
and just.
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JURY DEMAND
Plaintiff demands a trial by jury of all issues triable pursuant to Rule 38 of the
Federal Rules of Civil Procedure.
Dated:
June 2, 2020
/s/ Kevin C. Riach
Kevin C. Riach (#0389277)
Dulce J. Foster (#0285419)
Pari I. McGarraugh (#0395524)
Jacob P. Harris (#0399255)
FREDRIKSON & BYRON, P.A.
200 South Sixth Street, Suite 4000
Minneapolis, MN 55402-1425
Telephone: 612.492.7000
dfoster@fredlaw.com
pmcgarraug[email protected]om
jharris@fredlaw.com
Adam W. Hansen (#0391704)
APOLLO LAW LLC
333 Washington Avenue North, Suite 300
Minneapolis, MN 55401
Telephone: 612.927.2969
adam@apollo-law.com
Teresa Nelson (#269736)
AMERICAN CIVIL LIBERTIES UNION
OF MINNESOTA
P.O. Box 14720
Minneapolis, MN 55414
Telephone: 651.529.1692
tnelson@aclu-mn.org
Attorneys for Plaintiff
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