A judge dismissed a lawsuit against the city of Cloquet, Carlton County and two former Cloquet police officers Jan. 4.
The lawsuit was filed against the city and county by Clarence Manuel Lozoya Jr. after he claimed he was falsely imprisoned in 2017 after an arrest.
In the claim, the defense stated Lozoya would not have entered a guilty plea if "impeachment evidence" against the arresting officer was disclosed prior to the plea being made.
In his opinion, Judge Eric Tosrund, dismissed all claims against the city and county, with some of the claims dismissed with prejudice, meaning they cannot be filed again.
The claims dismissed with prejudice include unreasonable search and seizure, malicious prosecution and a failure to supervise.
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In his opinion, Tosrund stated it was clear “the Constitution does not require the government to to disclose material impeachment evidence prior to entering a plea agreement with a criminal defendant.”
Tosrund’s opinion statement also states Lozoya’s complaint includes no federal violation other than not disclosing impeachment information.
Lozoya’s complaint included injuries and damages due to a civil rights violation, however, it was due to “wrongfully failing to provide exculpatory evidence,” according to Tosrund.
The initial complaint hinged on the fact that former Cloquet police officer Scott Beckman had a Brady violation against himself that was not disclosed to the defense attorney before a guilty plea was made.
Brady v. Maryland is a 1963 Supreme Court case that requires the disclosure of exculpatory material to defendants in criminal prosecutions, including misconduct findings involving law enforcement.
In February 2016, an outside investigator concluded that Beckman lied to a superior officer and falsified an application for a search warrant. After leaving the department under a separation agreement in December 2018, the Carlton County Attorney’s Office said 18 cases involving Beckman were dismissed; four cases were submitted for review and not charged; and 25 additional cases were reviewed.
Lozoya was released from prison in February 2019 because of Beckman's involvement in the case. Lozoya was arrested again in 2020 on charges of felon in possession of an electronic incapacitation device; refusal to submit to a chemical test; fourth-degree driving while impaired; and several other misdemeanors. Most recently, Lozoya was arrested Nov. 3 for a probation violation.
As a judgment was passed on the case, the defendant now has 30 days to decide whether or not they will appeal.
