Eighth Circuit Affirms Dismissal in Ricky Cobb II Shooting: A
Case Study in Qualified Immunity
On July 31, 2023, a routine traffic stop for a missing headlight escalated into a fatal shooting on Interstate 94 in Minneapolis. Minnesota State Trooper Ryan Londregan shot and killed Ricky Cobb II after Cobb, informed he was under arrest for a felony protective-order violation, shifted his car into drive while another trooper, Brett Seide, was leaning halfway inside the vehicle.
Cobb’s estate sued both troopers under 42 U.S.C. § 1983, alleging unreasonable seizure and excessive force in violation of the Fourth Amendment. The case turned entirely on qualified immunity — the doctrine that shields officers from civil liability unless their conduct violated a constitutional right that was “clearly established” at the time.
U.S. District Judge Nancy Brasel dismissed the claims against Seide and Londregan in separate orders (October 2024 and January 2025, respectively), relying heavily on body camera and dash camera footage that she found “blatantly contradicted” the complaint’s characterization of events. Rather than accepting the plaintiff’s account at face value — the usual rule at the motion-to dismiss stage — Judge Brasel conducted her own frame-by-frame review of the recordings and concluded that Cobb’s decision to shift into drive after being told he was under arrest gave the troopers an objectively reasonable basis to perceive a threat, regardless of his actual intent.
On the assisting-officer doctrine, she held that Londregan was entitled to rely on Seide’s determination that Ramsey County had authorized an arrest, even though the phone call establishing that authorization was only half-audibleon the recordings.
On July 7, 2026, the Eighth Circuit affirmed on all counts, adopting Judge Brasel’s reasoning almost point for point: reasonable suspicion supported extending the stop, arguable probable cause supported the arrest, and deadly force was objectively reasonable given a moving vehicle with an officer partially inside it.
The panel’s opinion underscores a recurring theme in qualified immunity litigation — plaintiffs must identify precedent with closely analogous facts, not general principles, to defeat immunity, and video evidence embraced by the pleadings can resolve factual disputes well before discovery ever begins. For practitioners, the case is a reminder that in an era of ubiquitous body cameras, the footage itself often decides the case long before a jury ever could.