The Eighth Circuit affirmed the Order of US District Court Judge Paul Magnuson dismissing a lawsuit arising from a mass arrest near Shepard Road during the 2008 Republican National Convention in St. Paul, MN. The Court joined the D.C. Circuit’s holding in Carr v. District of Columbia, 587 F.3d 388 (D.C. Cir. 2009) which found probable cause for a mass arrest “is satisfied if the officers have grounds to believe all arrested persons were a part of the unit observed violating the law.” Based on the video footage, the Eighth Circuit found a reasonable officer could conclude the individuals at the intersection were acting together and that they intended to break through the police line in an attempt to access downtown St. Paul. It was also reasonable for officers to believe, “that the group, as a whole, was committing one or more offenses under state law, including third degree riot and unlawful assembly.” The Court found the detention of individuals in a nearby park was “reasonably necessary to achieve the purpose of the temporary seizure.” The City of St. Paul and the defendant officers were represented by Jon K. Iverson and Susan M. Tindal.