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8th Circuit Affirms Summary Judgment in Iowa Police Excessive Force Case

The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's summary judgment ruling dismissing civil rights claims against Dickinson County, Iowa, and two law enforcement officers. Ryan Wolterman had sued under federal civil rights statutes following a November 2020 incident involving Deputy Sheriff Shawn Syverson.

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5 min readcourtlistener
Seal of the Eighth Circuit Court of Appeals

Case Information

Case No.:
24-1482

Key Takeaways

  • Eighth Circuit affirmed summary judgment dismissing Section 1983 civil rights claims against Iowa law enforcement
  • Case stemmed from November 2020 incident involving Deputy Sheriff Shawn Syverson in Arnolds Park, Iowa
  • District court had granted summary judgment for all defendants including sheriff's office and county

The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's summary judgment ruling dismissing civil rights claims against Dickinson County, Iowa, and two law enforcement officers in a case stemming from a November 2020 incident at a bar in Arnolds Park, Iowa.

In *Ryan Wolterman v. Shawn Syverson* (8th Cir. 2026), the appeals court upheld the lower court's decision to grant summary judgment in favor of Deputy Sheriff Shawn Syverson, Sheriff Gregory Baloun, and Dickinson County. Wolterman had filed suit under 42 U.S.C. § 1983, the federal civil rights statute, as well as Iowa state law.

The case originated from events on Nov. 8, 2020, when Deputy Syverson responded to a call about a fight at the Captain's Getaway bar in Arnolds Park. According to court documents, after arriving at the scene, Syverson spoke with a female witness who pointed toward an individual wearing a green shirt who was walking away from the area, approximately 100 yards away.

Deputy Syverson testified that he got in his patrol car to follow the individual down an alley but lost sight of the person. His body camera began recording while he was in the patrol car. Believing the individual "had either fled or was hiding," Syverson began searching, first on foot and then again in his patrol car.

While conducting his search in the patrol vehicle, Deputy Syverson spotted Ryan Wolterman walking on the sidewalk. The court documents indicate this encounter led to the incident that formed the basis of Wolterman's subsequent lawsuit.

Wolterman sued Syverson individually and in his official capacity as a law enforcement officer, Sheriff Baloun individually and in his official capacity, and Dickinson County. The plaintiff alleged violations of his federal civil rights under Section 1983, which allows individuals to sue state and local officials for constitutional violations, as well as claims under Iowa law.

The case proceeded through the U.S. District Court for the Northern District of Iowa - Western Division, where the defendants sought summary judgment. Summary judgment is granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.

The district court granted summary judgment in favor of all defendants, effectively dismissing Wolterman's claims. Wolterman appealed this decision to the Eighth Circuit Court of Appeals, which has jurisdiction over federal appeals from Iowa, Arkansas, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota.

The three-judge panel that heard the appeal consisted of Circuit Judges Smith, Gruender, and Shepherd. Judge Gruender authored the opinion for the court. The case was submitted to the panel on Sept. 17, 2025, and the decision was filed on Jan. 14, 2026.

In affirming the district court's summary judgment ruling, the Eighth Circuit concluded that the lower court properly dismissed Wolterman's claims against the law enforcement officers and the county. The appeals court's decision means that Wolterman's lawsuit has been definitively resolved in favor of the defendants.

Section 1983 lawsuits against law enforcement officers and municipalities are common in federal court and typically involve allegations of excessive force, false arrest, or other constitutional violations. These cases often turn on complex questions of qualified immunity for individual officers and municipal liability standards for local governments.

For individual officers to be held liable under Section 1983, plaintiffs must show that the officers violated clearly established constitutional rights. Law enforcement officers are generally entitled to qualified immunity unless they violated clearly established law that a reasonable officer would have known.

Municipal defendants like Dickinson County face a different legal standard. Under *Monell v. Department of Social Services* (S. Ct. 1978), municipalities cannot be held liable under Section 1983 based solely on the actions of their employees. Instead, plaintiffs must show that a municipal policy, custom, or practice caused the constitutional violation.

The Eighth Circuit's affirmance of summary judgment suggests that Wolterman was unable to establish the necessary elements for his federal civil rights claims or his state law claims. While the court documents do not detail the specific reasoning for the affirmance, summary judgment typically indicates that the evidence, viewed in the light most favorable to the plaintiff, was insufficient to support the claims.

This decision joins a substantial body of Eighth Circuit case law addressing Section 1983 claims against law enforcement. The circuit has generally been considered more favorable to law enforcement defendants compared to some other federal circuits, particularly in cases involving qualified immunity determinations.

The case represents another example of the challenges plaintiffs face in civil rights litigation against law enforcement officers and their employers. Federal courts have increasingly granted summary judgment in favor of defendants in such cases, particularly where qualified immunity applies to individual officers.

Wolterman's case has now concluded with the Eighth Circuit's affirmance, unless he seeks further review from the Supreme Court through a petition for certiorari. The high court accepts only a small percentage of such petitions and typically does so only in cases involving important legal questions or conflicts between circuit courts.

Topics

Section 1983 civil rights lawsuitLaw enforcement conductSummary judgmentPolice stop and detention

Original Source: courtlistener

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