Rued v. Hudson

Background

Joseph Daryll Rued, W.O.R., Scott Daryll Rued, and Leah Jean Rued filed this case after state-court proceedings concerning W.O.R.’s custody. The complaint named state judicial officers, Minnesota Attorney General officials, private attorneys and a law firm, Catrina M. Rued, the Hennepin County Clerk of Court, a police officer, and CornerHouse. The plaintiffs alleged misconduct involving evidence, child-protection investigations, court filings, and the handling of custody-related proceedings. They sought damages and declaratory relief.

All but the Hennepin County Clerk of Court moved to dismiss or sought other relief. The plaintiffs also requested reassignment, sanctions against counsel, disqualification of counsel, and consolidation with related cases.

Jurisdiction and Rooker–Feldman

The court applied the Rooker–Feldman doctrine, a jurisdictional rule that prevents federal district courts from acting as appeals courts for state-court judgments. The court concluded that the plaintiffs’ requested relief could not be granted without effectively deciding that Minnesota state courts mishandled the proceedings that determined W.O.R.’s custody. It therefore concluded that the claims were closely connected to the earlier state-court decisions and that the federal court lacked jurisdiction.

The court rejected the plaintiffs’ arguments that their claims were independent, that ongoing related state proceedings prevented application of the doctrine, and that their federal claims had never been addressed. The court recommended dismissing the action without prejudice for lack of jurisdiction under Rooker–Feldman.

Filing restriction

The court recommended restricting Joseph Rued, Scott Daryll Rued, and Leah Jean Rued from filing new cases in the District of Minnesota concerning Joseph Rued’s divorce or W.O.R.’s custody unless they first obtained approval from a judicial officer in the District or were represented by counsel. The restriction would not apply to unrelated nonfrivolous litigation. The court also recommended placing those three plaintiffs on the District’s restricted-filer list. The recommendation did not include W.O.R.

In reaching this recommendation, the court considered the plaintiffs’ history of related litigation, the lack of an objectively reasonable basis for continuing the litigation, the burden on opposing parties and the courts, and whether lesser measures would adequately protect the judicial process. The court stated that the plaintiffs had filed five related federal cases, four of which had already been dismissed, and that Joseph Rued had previously been designated a frivolous litigant in state court.

Other rulings and recommendations

The court ordered the reassignment motion denied as moot because the requested reassignment had already occurred. It recommended that the motions to dismiss filed by the state defendants and Jamie Pearson be granted to the extent they relied on Rooker–Feldman and otherwise denied as moot. It recommended that the motion filed by Catrina M. Rued, Beth Wiberg Barbosa, Charlie R. Alden, and Gilbert Alden Barbosa PLLC be granted to the extent it sought the filing restriction and otherwise denied as moot.

It recommended that the remaining listed motions—including CornerHouse’s motion to dismiss, the plaintiffs’ responsive motions, the plaintiffs’ sanctions and disqualification motions, and the motion to consolidate—be denied as moot. It also recommended denying the request for monetary sanctions. The report explained that it was unclear whether the cited sanctions statute applied to people representing themselves without lawyers and that the proposed filing restriction might prevent further repetitive litigation.

Status of the decision

The document is an order and report and recommendation signed by United States Magistrate Judge Tony N. Leung. It is not a final district-court judgment and is not directly appealable to the Court of Appeals. The notice stated that a party could file specific written objections within 14 days after being served with the report and recommendation.