Shaik v. Finnegan

Background

Abdul-Jameer Shaik’s Complaint named Laura Finnegan, Ryan Anderson, two police officers identified by badge numbers 1391 and 1219, Kelly L. Olmstead, and Treye D. Kettwick. The Complaint broadly alleged that Shaik’s September 2023 arrest was a kidnapping without a valid warrant or due process. It also alleged that Finnegan and Anderson took property during a search of his car. Separately, Shaik alleged that the two officers identified by badge numbers 1391 and 1219 assaulted him, attempted to kidnap him, and took his phone during a May 2024 incident at the Ramsey County Courthouse.

Shaik’s state criminal case arising from the September 2023 events was still proceeding in Minnesota state court, with a jury trial set for later in the month. Shaik sought damages of more than $3 million and asked the federal court to dismiss that state prosecution. He later filed a Notice of Default Judgment and Motion to Dismiss with Extreme Prejudice, asserting that a default had occurred because the federal court had not yet entered an order.

Misjoinder

The court held that the Complaint improperly joined separate claims and defendants. Federal Rule of Civil Procedure 18 allows a party to bring multiple claims against one opposing party. But when a plaintiff names multiple defendants, Rule 20(a)(2) requires the claims against those defendants to arise from the same transaction or occurrence and to involve a common question of law or fact.

The court identified two separate sets of events: the September 2023 arrest and ongoing prosecution, involving potential claims against Finnegan, Anderson, Olmstead, and Kettwick; and the May 2024 courthouse incident, involving the two officers identified by badge numbers 1391 and 1219. The court found no plausible common question of law or fact connecting all defendants as the Complaint was then presented.

The court ordered Shaik to submit a one-page filing within 10 days of the Order’s date stating whether he wanted the case to proceed over the September 2023 arrest and prosecution or, alternatively, the May 2024 courthouse incident. For the group of events he did not select, the court noted that Shaik could consider bringing a separate lawsuit. If Shaik failed to submit the required filing, the court would recommend dismissing this action under Federal Rule of Civil Procedure 41(b) for failure to prosecute.

Motion to Dismiss and Default

The court denied Shaik’s Notice of Default Judgment and Motion to Dismiss with Extreme Prejudice. Under Rule 55(a), a defendant’s default may be entered when the defendant has failed to plead or otherwise defend after being served. The court explained that none of the defendants had been served because the court was still reviewing the Complaint under its responsibilities under 28 U.S.C. § 1915. Consequently, no relevant failure to defend had occurred.

The court also warned that, under the rule requiring federal courts generally to refrain from interfering with ongoing state proceedings, it would be very likely to refuse to interfere with Shaik’s state prosecution if he chose to proceed with claims challenging his arrest and prosecution.

Disposition

The court ordered Shaik to choose which set of events would remain the focus of this action, stated that it would recommend dismissal for failure to prosecute if he did not file the required response, and denied the Notice of Default Judgment and Motion to Dismiss with Extreme Prejudice. The Order did not resolve the merits of Shaik’s underlying claims.