Spottswood v. Washington County, MN
- Jerry Blackwell
- 0:24-cv-00224
- U.S. District Court · District of Minnesota
- 2
In Spottswood v. Washington County, MN, Judge Blackwell dismissed injunctive-relief claims without prejudice and stayed the remaining action pending state criminal proceedings.
Shawn Clarke Spottswood’s federal action was partly dismissed and otherwise stayed; he must notify the federal court after the related Washington County state court criminal proceedings, including appeals, conclude.
What happened
Spottswood v. Washington County, MN concerns an amended complaint challenging proceedings in Washington County state court. The opinion identifies Washington County, MN, and Zoom Inc. as defendants and says the challenged state criminal matter was still pending.
Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation, and no party filed timely objections. District Judge Jerry W. Blackwell reviewed the recommendation for clear error and found none.
Judge Blackwell accepted the recommendation, dismissed the amended complaint without prejudice to the extent it sought injunctive relief, and stayed the rest of the action until the state court proceedings—including any appeals—are finally resolved. Spottswood must notify the federal court within 30 days after that matter ends.
The detailed version
- Spottswood v. Washington County, MN · No. 0:24-cv-00224
- Jerry W. Blackwell
- July 11, 2024
Background
Shawn Clarke Spottswood filed an amended complaint naming Washington County, MN, and Zoom Inc. as defendants. The order states that the amended complaint challenged Spottswood’s Washington County state court criminal proceedings. The opinion does not identify the specific legal claims or the requested relief beyond injunctive relief.
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on June 17, 2024. No objections were filed within the permitted time. Under the review standard described in the order, the district court reviewed the recommendation for clear error.
Ruling
The court found no clear error and accepted the Report and Recommendation. It dismissed the amended complaint without prejudice to the extent it sought claims for injunctive relief. The order does not add a prejudice designation to any other part of the case.
The remainder of the action was stayed pending final resolution of the state court criminal proceedings challenged by the amended complaint, including any appeals. Spottswood was ordered to notify the federal court within 30 days after those proceedings conclude. The clerk was also directed to send a certified copy of the order to the Washington County District Court, Tenth Judicial District.
Effect of the Order
The federal action continues only in a stayed posture as to its remaining claims or requests for relief. The injunctive-relief claims were dismissed without prejudice, while the order does not state a final disposition for the remainder of the action.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.