23.  Plaintiff seeks class certification pursuant to Fed. R. Civ. P. 23(a) and (b)(1)(B), (2) and  (3) related to all claims for which monetary, injunctive, and declaratory relief is sought.   24.  This Class is defined as: “All peaceful protestors who have been injured as a result of  Defendants’ actions and who have thereafter been reluctant to speak out against police violence  against citizens.”    25.  A class action is the only practicable means by which Plaintiffs and unknown members of  the class can challenge Defendants’ illegal actions.   26.  As set forth below, this action satisfies the numerosity, commonality, typicality, and  adequacy requirements of Rule 23(a).     28.  The Class consists of hundreds of people who cannot or will not be able to afford to  retain counsel and litigate their cases though to judgment. The class is forward-looking with the  potential for new members to join the Class on an ongoing basis as citizens continue to be  subjected to such behavior.     29.  Finally, members of the proposed Class are spread out across the metro area and  potentially the state and include hundreds of low-income individuals who lack financial  resources to bring an independent action or to be joined in this action. Putative members of the  class include countless young adults, persons presently engaged in job transitions, and persons  searching for work after recent COVID-19 layoffs: It is reasonable to assume such persons  would also be unable to afford counsel to bring their own separate action against Defendants.     30.  Commonality: All persons comprising the proposed Class are equally suited in that all  individuals are or were protected under federal law.   32. Common questions of law include:   a. Whether Defendants acted in violation of the protestors’ civil rights.   b. Whether the Defendants committed acts of unnecessary force.   c. Whether the Defendants committed acts of police brutality.  d. Whether individuals have suffered harm sufficient to bring their claims in court.   33. The relief sought for the proposed Class is common to all members of that respective Class.  Plaintiffs seek relief enjoying the police from using such tactics against protestors. They  additionally seek: (a) an order preventing Defendants from using force against individuals  solely on the basis they disagree with their political views concerning police tactics, (b) an  order prohibiting the “corral and combat” strategy, and (c) monetary relief for past injuries.   34. Typicality: The claims of Plaintiff are typical of the claims of the Class as Plaintiff and all  members have suffered and will continue to suffer harm from the complained of tactics of the  Minneapolis police department.    35. Because Plaintiff and the proposed class members challenge the same conduct of Defendants,  Defendants will likely assert similar defenses against Plaintiff and the proposed Class  members. Moreover, the answer to whether Defendants’ tactics are unlawful under §1983  will determine the success of the claims of the named Plaintiff and every other proposed  Class member. If Plaintiff succeeds in the claim that Defendants have violated §1983, that  ruling will likewise benefit every other member of the proposed Class.   37. Rule 23(b)(2): Class action status under Rule 23(b)(2) is appropriate because the Defendants  have acted or failed and/or refused to act on grounds that generally apply to the proposed  Class, such that preliminary and final monetary, injunctive, and declaratory relief is  appropriate and necessary with respect to each member of the Class.  Specifically, pursuant  to §1983, the Defendants have systematically deprived individuals of their constitutional  rights, privileges and immunities. The acts and omissions of Defendants are generally  applicable the proposed Class.    38. Accordingly, (a) a declaration that Defendants have infringed on the first amendment rights  of members of the class, (b) an injunction prohibiting Defendants from continuing such  behavior, and (c) monetary relief for all individuals harmed by Defendants’ illegal actions to  date, would benefit every member of each of the proposed Class.   40. Plaintiff realleges the above allegations as if hereinafter set forth in full and further states and  alleges as follows:   41. This claim arises under Title 42 of the United States Code (Civil Rights Act of 1964, as  amended), including but not limited to §1983.   42. Defendants acted alone and/or together (2 or more in concert), and one or more of them  committed some act in furtherance of the conspiracy to violate Plaintiff’s rights and those of the  Class as peaceful protestors (and Plaintiff and proposed class members  were damaged).   44. Defendants (and each of them) knew they were violating the federal law and constitutional  rights of Plaintiff and/ or acted with intent and/ or deliberate indifference to the rights of  Plaintiff as noted above, or with malice.   45. The Defendants acted under color of law (public officials acting alone and/or conspiring with  private officials) of a statute, ordinance, regulation, resolution, policy, custom or usage when  they deprived Plaintiff of his Constitutional rights, privileges, and immunities.   46. As a direct and proximate result of the Defendants' conduct, inaction, policy or customs as set  forth in more detail above, Plaintiff and other protestors suffered the deprivation of their  constitutional and/or federal statutory rights and suffered personal injuries, including physical  injury, humiliation, mental anguish and suffering, and emotional distress.   Violation of 42 U.S.C. §1983  (Against all Defendants)  (On behalf of Plaintiff and the Class)  