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8th Circuit Upholds Dismissal of Excessive Force Claim Against Minneapolis Officer

The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's dismissal of an excessive force lawsuit filed by Debbie Tucker against Minneapolis Police Officer Alejandro Boldo. Tucker claimed Boldo used excessive force when he closed a car door on her leg during a traffic stop.

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Seal of the Eighth Circuit Court of Appeals

Case Information

Case No.:
No. 25-1091

Key Takeaways

  • Eighth Circuit affirmed district court's dismissal of excessive force claim against Minneapolis police officer
  • Incident occurred during traffic stop of vehicle illegally parked in handicapped spot with driver who had outstanding felony warrants
  • Officer closed car door on plaintiff's leg when she attempted to exit vehicle during arrest
  • Court found officer's actions were reasonable given circumstances and plaintiff's resistance to lawful orders

The U.S. Court of Appeals for the Eighth Circuit affirmed a district court's dismissal of an excessive force lawsuit against Minneapolis Police Officer Alejandro Boldo, ruling that his actions during a traffic stop did not violate constitutional protections. The case, *Tucker v. Boldo* (8th Cir. 2026), involved claims that the officer used excessive force when he closed a car door on plaintiff Debbie Tucker's leg.

The incident began when a Minneapolis police officer noticed a vehicle parked illegally in a handicapped spot without proper identification tags. Inside the car were Tucker, her daughter, and a family friend who was driving. The driver had multiple outstanding felony arrest warrants, which officers discovered during their investigation.

According to the court record, by the time Officer Boldo arrived at the scene, another officer was already placing the driver in handcuffs. A woman at the scene was shouting "no, he don't!" and "bullshit!" as the arrest proceeded. As Boldo approached the passenger side of the vehicle, he observed Tucker beginning to open the car door.

To prevent Tucker from exiting the vehicle, Boldo blocked the door and pushed back on it, which resulted in catching her foot in the process. Tucker responded by yelling, "Ow! Why you smashing my foot?" The officer then ordered her to "stay in the car" and "pull it in," but Tucker did not comply with these instructions.

Instead of following Boldo's orders, Tucker cursed at the officer and attempted to open the car door a second time. Boldo again blocked the door, which prompted Tucker to curse, wave her hands, and attempt to scratch the officer's face. The confrontation only ended when Tucker's daughter intervened, after which Boldo walked away from the vehicle.

Following the incident, Tucker filed a federal lawsuit against Officer Boldo in the U.S. District Court for the District of Minnesota. She alleged that by closing the door on her foot, the officer had used excessive force in violation of her constitutional rights. The case was heard by the Honorable Jeffrey M. Bryan, who ruled in favor of the officer and dismissed Tucker's claims.

Tucker appealed the district court's decision to the Eighth Circuit Court of Appeals. The appeal was submitted on Oct. 23, 2025, and the court issued its opinion on Feb. 2, 2026. The three-judge panel consisted of Circuit Judges Gruender, Stras, and Kobes, with Judge Stras writing the majority opinion.

In a brief but decisive opinion, the Eighth Circuit agreed with the lower court's assessment of the case. "Debbie Tucker claims that Officer Alejandro Boldo used excessive force when he closed a car door on her leg," Judge Stras wrote. "The district court thought otherwise, and so do we."

The ruling represents the latest development in ongoing litigation involving allegations of police misconduct and excessive force. Courts applying Fourth Amendment excessive force analysis typically examine whether an officer's actions were objectively reasonable under the circumstances, considering factors such as the severity of the threat posed, the immediacy of the threat, and whether the suspect was actively resisting or attempting to flee.

In this case, the appeals court apparently found that Boldo's actions in preventing Tucker from exiting the vehicle during an active arrest situation were justified under the circumstances. The officer was responding to a situation involving a driver with outstanding felony warrants, and Tucker was actively resisting his orders to remain in the vehicle.

The decision reflects the Eighth Circuit's approach to excessive force claims involving relatively minor physical contact during police encounters. Courts have generally held that officers have authority to control the movement of individuals during traffic stops and arrests, particularly when public safety concerns are present.

The ruling also highlights the challenges plaintiffs face when bringing excessive force claims based on relatively minor injuries or brief physical contact with law enforcement. To succeed on such claims, plaintiffs must demonstrate that the officer's actions were objectively unreasonable and that any force used was disproportionate to the circumstances.

Tucker's case joins a growing body of Eighth Circuit precedent addressing the boundaries of permissible police conduct during traffic stops and arrests. The court's affirmance suggests that officers retain significant discretion to control suspects' movements and prevent interference with ongoing law enforcement activities.

The brief nature of the published opinion indicates that the appeals court viewed the case as relatively straightforward, with the facts not supporting Tucker's excessive force allegations. The panel's unanimous agreement with the district court's dismissal further underscores their view that Boldo's actions fell within acceptable bounds of police conduct.

For Tucker, the ruling represents the end of her federal civil rights lawsuit unless she chooses to petition the Supreme Court for review, though such petitions are rarely granted in cases involving fact-specific determinations about police conduct during routine enforcement activities.

Topics

excessive forcepolice misconductSection 1983 civil rightsbatteryqualified immunitysummary judgment

Original Source: courtlistener

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