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CASE 0:11-cv-00646-JNE-TNL Document 26 36 Filed 01/04/12 03/15/12 Page 28 of 35and severally, act under color of law in the course and scope of their employmentas Minneapolis police officers.197. Defendants Menter, Officers 1 – 10, and Minneapolis, jointly and severally,inflict common law false imprisonment upon Ms. Crowder without warrant,without consent, and without other lawful authority.198. Defendants inflict damages upon Tiffany Crowder.CLAIM XIV: DATA PRACTICES ACT199. Plaintiffs reallege and reassert each and every claim and averment above.200. Defendants City of Minneapolis and MPHA, jointly and severally, create,store, and disseminate false, inaccurate individual data of and concerning Ms.Crowder in violation of Minn. Stat. §§ 13.04 subd. 4 and 13.05 subd. 5.201. Defendants inflict damages upon plaintiff Tiffany Crowder in violation ofMinn. Stat. § 13.08 subd. 1.CLAIM XV: DATA PRACTICES ACT (MINNEAPOLIS)202. Plaintiffs reallege and reassert each and every claim and averment above.203. Defendant City of Minneapolis fails to provide all public or private data ofand concerning Ms. Crowder on a timely basis.CLAIM XVI: DATA PRACTICES ACT (MPHA)204. Plaintiffs reallege and reassert each and every claim and averment above.205. Defendant MPHA fails to provide all public or private data of and concerningMs. Crowder on a timely basis.28
CASE 0:11-cv-00646-JNE-TNL Document 26 36 Filed 01/04/12 03/15/12 Page 29 of 35CLAIM XVII: First, Sixth, and Fourteenth Amendment to the United StatesConstitution, with reference to 42 U.S.C. § 1437f, as Protected through 42U.S.C. § 1983206. Ms. Crowder realleges and reasserts each and every claim and avermentabove.207. 24 C.F.R. §§ 982.552(c) and 982.555, with respect to their provisions forhearings for termination of tenant-based § 8 housing assistance program benefits,as written, do not provide for compulsory appearance of witnesses, do not enshrinethe clearly established right to confront hostile witnesses when a protected libertyinterest is at stake, per Goldberg v. Kelly, 397 U.S. 254 (1971), do not provide foran electronically recorded or court reporter-transcribed verbatim hearing –necessary for full and fair certiorari review of the record of a termination hearingby the Minnesota Court of Appeals, in violation of the Sixth and FourteenthAmendment guarantees of Confrontation and Due Process, as well as guaranteesof due process under Minn. Const. Art. I, §§ 7 and 8.208. MPHA made its determination in part on the basis of documents not providedto Ms. Crowder prior to the hearing.209. MPHA made its determination in part, notwithstanding documents in itspossession, but not provided to Ms. Crowder prior to the hearing, that militatedagainst revocation of Ms. Crowder’s § 8 benefits.210. MPHA made its determination, in part, upon hearsay evidence without givingMs. Crowder the opportunity to cross-examine the declarant(s), viz., police29
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