Goyette v. City of Minneapolis

Background

Nine journalists and other news-media members brought civil-rights claims against law-enforcement officials and agencies concerning their coverage of protests following the police killings of George Floyd and Daunte Wright. The plaintiffs sued David Hutchinson, then the Hennepin County Sheriff, in both his individual and official capacities.

The court had previously denied Hutchinson’s motion for summary judgment on both types of claims and had denied qualified immunity on some of the individual-capacity claims. Qualified immunity is a legal protection that can prevent an official from being personally sued for damages in some circumstances. Hutchinson filed an interlocutory appeal—an appeal before the case was finished—challenging the denial of qualified immunity and related legal issues involving the official-capacity claims.

Plaintiffs’ Motion

While the appeal was pending, the plaintiffs moved to voluntarily dismiss all claims against Hutchinson in his individual capacity. They sought to proceed to trial against him in his official capacity without interlocutory appellate review of the qualified-immunity ruling. The plaintiffs requested dismissal with prejudice, meaning those individual-capacity claims could not be brought again. Hutchinson opposed the motion and argued, among other things, that the plaintiffs were improperly using dismissal to avoid appellate review.

Jurisdiction

The court explained that filing a notice of appeal generally removes the district court’s authority to decide matters involved in the appeal. The district court may still decide collateral matters—issues separate from the appeal, such as some fee, sanctions, or record-sealing matters. It concluded that this dismissal request was not sufficiently separate because granting it could affect the pending appeal, including by making issues in that appeal moot.

The court therefore held that it lacked jurisdiction to decide the plaintiffs’ motion directly. It also rejected the plaintiffs’ argument that the appeal was frivolous, explaining that the Eighth Circuit, rather than the district court, would decide that issue.

Indicative Ruling

Under the federal rules governing matters affected by a pending appeal, a district court without jurisdiction may defer the motion, deny it, or issue an indicative ruling stating that it would grant the motion if the appellate court remands for that purpose. The court selected the third option.

The court concluded that Rule 41 permits dismissal of all claims against a particular defendant, even when other claims and defendants remain in the case. It also stated that Hutchinson’s other objections were more appropriately addressed by the Eighth Circuit. The Eighth Circuit could decide whether and when to send the matter back, and could retain the case for consideration of the interlocutory appeal.

Because the plaintiffs requested dismissal with prejudice and the court found no exceptional circumstances, it stated that it intended to grant the dismissal without awarding Hutchinson costs or attorney’s fees if the case were remanded for that purpose.

Disposition

The order states that the plaintiffs’ motion to voluntarily dismiss with prejudice the individual-capacity claims against Hutchinson and for an indicative ruling was GRANTED in part and DENIED in part:

1. The court lacked jurisdiction to grant the motion to dismiss at that time. 2. The court would grant the motion if the Eighth Circuit remanded the matter for that purpose under the applicable federal rules.

The order did not itself dismiss the individual-capacity claims.