Johnson v. City of Minneapolis, 901 F.3d 963, 971 (8th Cir. 2018) (“We have said repeatedly—before Officer Heiple arrested Johnson—an officer ‘cannot avoid minimal further investigation if it would have exonerated the suspect.’”).
Ross v. City of Jackson, Missouri, 897 F.3d 916, 922 (8th Cir. 2018) (“In this case, even a ‘minimal further investigation’ would have revealed that Ross’s post was not a true threat.”).
Binion v. City of St. Paul, 788 F. Supp. 2d 935, 943 (D. Minn. 2011) (“According to law that was clearly established at the time of Binion’s arrest, the officers had a duty to reasonably investigate before arresting Binion.”).
St. James v. City of Minneapolis, Minn., CIV. 05-2348 DWF/JJG, 2007 WL 2908115, at *6 (D. Minn. Oct. 2, 2007) (stating that “there are genuine issues of material fact with respect to whether minimal further investigation would have exonerated St. James or whether a reasonable officer would have known that St. James’ arrest violated his clearly established right to be not to be arrested without probable cause”).
Womack v. City of Bellefontaine Neighbors, 193 F.3d 1028, 1031 (8th Cir. 1999) (“Evidence tending to show Womack did not commit the charged crimes is relevant to whether the officers had probable cause to arrest her because officers contemplating an arrest cannot ‘disregard plainly exculpatory evidence, even if substantial inculpatory evidence (standing by itself) suggests that probable cause exists.’”).
Kuehl v. Burtis, 173 F.3d 646, 650 (8th Cir. 1999) (stating that “law enforcement officers have a duty to conduct a reasonably thorough investigation prior to arresting a suspect, at least in the absence of exigent circumstances and so long as ‘law enforcement would not [be] unduly hampered … if the agents … wait[ ] to obtain more facts before seeking to arrest.’”).