Alexander v. Experian Information Solutions, Inc.

Background

Mercedes Alexander initially sued several credit-reporting agencies, a debt-collection agency, and Halverson and Blaiser Group, Ltd. The opinion identifies Halverson as a property-management company. Alexander’s original complaint asserted one claim against Halverson under the Minnesota Consumer Fraud Act, Minnesota Statutes section 325F.69.

After Halverson raised concerns about the complaint’s failure to provide the detail required for fraud claims, the parties agreed that Alexander could amend her complaint by March 4, 2024. A magistrate judge approved that agreement and set the same deadline. Alexander filed an amended complaint on March 15, 2024. The amended complaint added four non-fraud claims, expanded the factual allegations, and included nineteen exhibits.

Amended Complaint

The court held that the amended complaint was not timely filed and struck it. Because the filing was untimely, the court did not decide Halverson’s separate argument that the amended complaint went beyond the scope of the parties’ agreement. The court stated that Alexander could later ask for permission to amend in a filing that complied with the Federal Rules of Civil Procedure and the District of Minnesota’s local rules.

Alexander argued that the deadline should be excused because counsel learned new information during settlement discussions, experienced a family health emergency, and received information from a Dakota County housing caseworker after the deadline. The court rejected those explanations. It also noted that Alexander could have asked the court for more time to add new claims if Halverson would not agree.

Motion to Dismiss

The court granted Halverson’s motion to dismiss the original complaint under Federal Rule of Civil Procedure 12(b)(6), but its stated basis for disposing of the remaining claim was jurisdictional discretion rather than a decision on the claim’s merits. The other defendants had already been dismissed by stipulation, leaving only the Minnesota Consumer Fraud Act claim against Halverson.

The court considered whether to exercise supplemental, also called pendent, jurisdiction over that state-law claim. Supplemental jurisdiction is a federal court’s authority to hear a related state-law claim in the same case. The court found that convenience and fairness were neutral, while comity and judicial economy favored declining jurisdiction. It reasoned that a state court was better suited to analyze the Minnesota claim and that the case remained at the pleading stage.

Order

Judge Jeffrey M. Bryan ordered that Alexander’s amended complaint be dismissed as untimely, granted Halverson and Blaiser Group, Ltd.’s motion to dismiss, and dismissed Alexander’s original complaint in its entirety, without prejudice. The order did not decide the merits of Alexander’s Minnesota Consumer Fraud Act claim.