Michael A. Leonard filed suit against the Town of Westborough, Police Chief Todd Minardi, and Officer Bodhan Bukhenik over his arrest on August 8, 2024, claiming violations of his First and Fourth Amendment rights along with various state law claims including malicious prosecution and defamation. The lawsuit appears to stem from what Leonard characterizes as retaliation for protected speech and an unlawful arrest involving excessive force.
In his motion filed in the U.S. District Court for the District of Massachusetts, Minardi argues the undisputed record shows he had no role in Leonard's encounter with Westborough police officers. The chief contends he 'did not participate, direct, or know about the Plaintiff's encounter with Westborough police officers on August 8, 2024,' according to the filing.
Minardi's legal team emphasized that supervisory liability cannot be established through mere respondeat superior theory, citing First Circuit precedent. As the motion states, 'The First Circuit is clear that a supervisor may not be held liable under section 1983 on the tort theory of respondeat superior,' referencing the court's decision in Guadalupe-Báez v. Pesquera.
The case involves claims spanning constitutional violations and state tort law, with Leonard alleging First Amendment retaliation, Fourth Amendment violations for unlawful arrest and excessive force, along with claims for malicious prosecution, defamation, loss of consortium, negligence, and harassment. Leonard is proceeding pro se in the litigation.
The defense motion argues there is 'no genuine dispute of material fact' regarding Minardi's lack of personal involvement, making him 'entitled to judgment as a matter of law.' The filing indicates defense counsel attempted to confer with Leonard in good faith before filing the motion but were unable to resolve or narrow the disputed issues.
The summary judgment motion represents a common defense strategy in civil rights cases against supervisors, where personal participation in the alleged constitutional violation typically must be shown. The First Circuit has consistently held that supervisory officials cannot be held liable under Section 1983 merely based on their position or the actions of subordinates.
Leonard's pro se status may complicate his ability to effectively respond to the legal arguments raised by Minardi's experienced civil rights defense team. The case highlights ongoing tensions between police accountability and the legal standards required to hold supervisory officials liable for officers' actions.