Quinlan v. Washington County

Background

Carsten Quinlan filed a complaint concerning child-abuse allegations and later criminal proceedings. The complaint was 47 pages long, contained 230 paragraphs, and included exhibits totaling 369 pages of text. Quinlan later filed an Amended Complaint that added claims and defendants, including the City of Woodbury, and named his minor children as plaintiffs. The two pleadings together were treated as a “Full Amended Complaint” of approximately 417 pages and 457 paragraphs.

The pleadings included the full names of Quinlan’s minor children, information about their medical care, a custody evaluation that had been treated as confidential, and identifying and personal information about jurors from Quinlan’s criminal trial. The complaint also included personal attacks on Kim Richardson. The state court had previously directed that certain information be kept confidential and returned the Amended Complaint because it identified jurors, but the opinion states that no revised Amended Complaint had been filed before removal to federal court.

The City Defendants moved under Federal Rule of Civil Procedure 12(e) for a more definite statement and under Rule 12(f) to strike the Complaint and Amended Complaint, or portions of them. They also moved concerning sealing. Quinlan agreed to correct several problems and proposed conditions for filing a new complaint.

Court’s analysis

Rule 12(e) permits a court to require a more definite statement when a pleading is so vague or unclear that the opposing party cannot reasonably prepare a response. The court found that the pleadings contained inconsistent and duplicative claims and that it was unclear which pleading was operative after the state court removed the Amended Complaint from its file. The court also found that the 417-page, 457-paragraph Full Amended Complaint did not satisfy Federal Rule of Civil Procedure 8’s requirement for a short, plain, concise, and direct statement of the claims.

The court further found that the pleading did not clearly state the factual basis for claims against each defendant. It identified duplicative claims, including overlapping negligence, witness-tampering, and gross-negligence allegations. The court also concluded that the jurors’ names and personal information were immaterial and improper, and that the personal attacks on Richardson were scandalous under Rule 12(f).

Ruling and required next steps

The court granted the City Defendants’ Motions for More Definite Statement and/or to Strike. The Clerk was directed to strike the Complaint and Amended Complaint from the record. The plaintiffs were allowed to file one second amended complaint by October 25, 2024.

The second amended complaint must be a standalone document, present facts chronologically, identify which plaintiffs and defendants are involved in each allegation, avoid duplicative or repetitive material, comply with the Federal and Local Rules, and contain no more than 10,000 words. It must refer to minors by initials and must not include jurors’ identifying information or irrelevant medical or custody information. Any filing referring to the children’s custody determination must be filed under seal with a redacted public version, and the custody evaluation and medical documents may not be attached to the second amended complaint.

The court stated that failure to meet the deadline or comply with the requirements could lead it to recommend dismissal without prejudice under Rules 8 and 41. The City Defendants’ Motion Re: Sealing was denied as moot, because the court struck the two pleadings; Docket Entries 2, 2-1, and 2-2 remained under seal. The court did not resolve the merits of Quinlan’s underlying claims.