Rued v. Hudson

Background

The plaintiffs brought this action seeking to overturn a Minnesota state-court award of sole custody over minor W.O.R. The opinion states that the case was one of four orders addressing the same underlying facts. The plaintiffs appeared without lawyers. The defendants included Natalie E. Hudson, Leonardo Castro, Carrie Lennon, Keith Ellison, Alec Sloan, Beth Barbosa, Charlie Alden, Gilbert Alden Barbosa PLLC, Catrina M. Rued, the Hennepin County Clerk of Court, Jamie Pearson, and CornerHouse.

Jurisdiction and dismissal

The court concluded that it lacked jurisdiction under the Rooker-Feldman doctrine, which limits federal district courts’ ability to review and overturn state-court judgments. The court relied on its explanation in a companion order, adopted Magistrate Judge Tony N. Leung’s report and recommendation, and overruled the plaintiffs’ objections.

The order states that the complaint was dismissed with prejudice for lack of jurisdiction. The defendants’ motions to dismiss were granted.

Sanctions and filing restriction

Defendant Jamie Pearson sought sanctions consisting of filing restrictions and monetary awards. The court found that the plaintiffs’ conduct warranted placement of Joseph Rued, Scott Rued, and Leah Rued on the District of Minnesota’s restricted filers list. The restriction prohibits them from filing new lawsuits, pleadings, or other papers in that district concerning their disputes with any defendant relating to the custody dispute unless they are represented by counsel licensed to practice before the federal court or obtain prior written approval from a federal district judge or magistrate judge in Minnesota.

The court did not place minor W.O.R. on the restricted filers list. It stated that the minor was unwillingly a party to the action and that the parties disputed whether the plaintiffs could file on the minor’s behalf. The court also stated that the restriction applies to attempts to circumvent the order by filing on W.O.R.’s behalf in the future.

The sanctions motion was granted in part and denied in part: the filing restriction was imposed, but no monetary sanctions were imposed at that time. The court warned that continued conduct could lead future courts to consider monetary sanctions.

Disposition

Judge John R. Tunheim ordered that the plaintiffs’ objection be overruled; the magistrate judge’s report and recommendation be adopted; the complaint be dismissed with prejudice for lack of jurisdiction; and the defendants’ motions to dismiss be granted. The court granted in part and denied in part Jamie Pearson’s sanctions motion, and denied all other pending motions as moot.