1 UNITED STATES DISTRICT COURT FOR THE ... - Star Tribune

CASE 0:11-cv-00646-JNE-TNL Document 26 36 Filed 01/04/12 03/15/12 Page 4 of 35being brought, without complaint against her, without indictment, withoutprosecution, and without judicial finding of probable cause.Tiffany Crowder sues the individual defendants, jointly and severally, fortheir actions under color of law in violation of her clearly established rights underthe Fourth and Fourteenth Amendment to be free from unreasonable seizure of herpersonal property without lawful authority, without authority under a searchwarrant, without plaintiff’s consent, and without any other exception under thelaw.Tiffany Crowder sues defendant David Menter in his individual capacityacting under color of law for violation of her clearly established First, Fifth, andFourteenth Amendment right to be free from coercion and unlawful deprivation ofher parental rights unto her minor child, T.C. T.C. and Tiffany Crowder suedefendant David Menter in his individual capacity acting under color of law forviolation of her clearly established First and Fourteenth Amendment right ofassociation with her mother.Plaintiffs additionally sue the individual defendants and the City ofMinneapolis, jointly and severally, for violations of their clearly established rightsunder the common law of Minnesota to be free from trespass, unlawful search,invasion of privacy, conversion, and battery. Plaintiffs sue the City ofMinneapolis pursuant to Minn. Stat. § 626.74 for bodily injuries inflicted upon T.C., property damage to the dwelling itself, and damage to chattels resultingdirectly from the execution of the search warrant and violent entry into their4