Reed v. Gillette Children's Specialty Healthcare
- Laura Provinzino
- 0:24-cv-03530
- U.S. District Court · District of Minnesota
- 9
In Jonah Reed v. Gillette Children’s Specialty Healthcare, Judge Provinzino granted dismissal, dismissing Title VI claims for failure to state a claim and state claims for lack of jurisdiction.
Jonah Reed’s claims against Gillette Children’s Specialty Healthcare were dismissed without prejudice. The Title VI claims were dismissed for failure to state a claim, and the Minnesota-law claims were dismissed for lack of jurisdiction.
What happened
Jonah Reed v. Gillette Children’s Specialty Healthcare concerned allegations about medical care Gillette provided to Reed’s minor child, G.F. Reed also alleged that Gillette staff harassed her and made a false child-protection report, and she claimed racial discrimination under Title VI of the Civil Rights Act of 1964.
Gillette asked the court to dismiss the amended complaint because it did not state a legally sufficient claim. The court dismissed Reed’s Title VI claims without prejudice because the complaint did not provide facts supporting racial discrimination. After dismissing the only federal claim, the court declined to decide Reed’s remaining Minnesota-law claims and dismissed them without prejudice for lack of jurisdiction.
Judge Laura M. Provinzino granted Gillette’s motion to dismiss. The order allowed Reed’s dismissed claims to be refiled because each dismissal was without prejudice, as stated in the order.
The detailed version
- Reed v. Gillette Children's Specialty Healthcare · No. 0:24-cv-03530
- Laura M. Provinzino
- Mar. 17, 2025
Background
Jonah Reed sued Gillette Children’s Specialty Healthcare over care provided to Reed’s minor child, identified in the opinion as G.F. Reed alleged that G.F. was admitted after a swallow study indicated that G.F. needed specialized formula and a feeding tube. Reed alleged that Gillette unnecessarily prolonged G.F.’s hospital stay, attempted to change G.F.’s formula without informing her, administered expired formula, left medical devices disconnected, and responded dismissively to her concerns. Reed left the hospital with G.F. despite a physician’s advice against discharge.
Reed also alleged that a Gillette nurse acted intimidatingly toward her in the parking lot and that a Gillette social worker made a baseless child-protection report in retaliation for Reed’s complaints. Reed asserted claims under Minnesota law concerning hospital care, harassment, and the report to Child Protection Services. The court construed the claims under the Minnesota statutes identified in the opinion, including Minn. Stat. §§ 144.651, 609.749, and 260E.08. Reed also asserted a claim under Title VI of the Civil Rights Act of 1964 and sought a federal investigation and $20 million in compensatory damages.
Reed initially filed the case in Minnesota state court, and Gillette removed it to federal court. Reed proceeded without a lawyer. She did not respond to Gillette’s motion to dismiss, although the court extended the response deadline to encourage a response.
Legal standard
Gillette moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The court accepted well-pleaded factual allegations as true and drew reasonable inferences for Reed, but it did not accept unsupported legal conclusions. Because Reed was proceeding without a lawyer, the court read her pleadings liberally, while still requiring factual allegations rather than bare conclusions.
Title VI claim
Title VI prohibits racial discrimination in programs receiving federal funding. The court held that Reed’s complaint did not plead enough facts to support a Title VI claim. Reed did not allege that a similarly situated person of another race received better treatment, and she did not allege facts showing that Gillette deliberately ignored known racial discrimination. The court concluded that the complaint did not allow a reasonable inference that Gillette’s conduct was racially motivated.
The court therefore dismissed Reed’s Title VI claims without prejudice for failure to state a claim upon which relief can be granted.
Minnesota-law claims and jurisdiction
The court had federal-question jurisdiction over the Title VI claim because it arose under federal law. The remaining claims arose under Minnesota law and could have been heard under supplemental jurisdiction, which permits a federal court to hear related state-law claims in the same case.
After dismissing the only federal claim, the court exercised its discretion to decline supplemental jurisdiction over Reed’s remaining Minnesota-law claims. The court dismissed those claims without prejudice for lack of jurisdiction. The court did not decide whether those state-law claims were legally sufficient.
Order
The court ordered that:
- Gillette’s motion to dismiss the amended complaint was GRANTED.
- Reed’s Title VI claims were DISMISSED WITHOUT PREJUDICE for failure to state a claim upon which relief can be granted.
- The remainder of Reed’s claims were DISMISSED WITHOUT PREJUDICE for lack of jurisdiction.
Judgment was ordered to be entered accordingly.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.