Patterson v. Minfield
- David Doty
- 0:25-cv-00699
- U.S. District Court · District of Minnesota
- 4
In Patterson v. Minfield, Judge Doty dismissed the case without prejudice for lack of jurisdiction and denied Patterson’s application to proceed without prepaying fees or costs as moot.
Arthur A. Patterson’s action against Dennis Minfield was dismissed without prejudice for lack of jurisdiction, and Patterson’s application to proceed without prepaying fees or costs was denied as moot. Hennepin County was not named in the caption, and the court did not clearly treat it as a defendant.
What happened
In Patterson v. Minfield, Arthur A. Patterson alleged that Dennis Minfield assaulted him, including by slapping him and causing hearing loss in one ear. The complaint also appeared to refer to Hennepin County, housing officials, discrimination, and breach of contract, and sought $25 million in damages.
The court found that Patterson had not identified a federal law or constitutional right involved in the case. The allegations might support state-law claims, but the complaint did not establish federal jurisdiction. The court also found that any possible discrimination claim was too unclear and unsupported to provide federal jurisdiction.
Judge David S. Doty dismissed the action without prejudice for lack of jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court also denied Patterson’s application to proceed without prepaying fees or costs as moot.
The detailed version
- Patterson v. Minfield · No. 0:25-cv-00699
- David Doty
- Mar. 13, 2025
Background
Arthur A. Patterson filed a complaint against Dennis Minfield and an application to proceed in federal court without prepaying fees or costs. Patterson alleged that Minfield assaulted him at least twice, including by slapping him and causing hearing loss in one ear. Although the caption named only Minfield, the complaint also appeared to suggest that Patterson intended to sue Hennepin County. Patterson appeared to allege that the County was responsible for his housing and that housing officials failed to act after he reported Minfield’s conduct. The complaint also suggested discrimination and breach-of-contract claims and requested $25 million in damages.
Jurisdiction
The court explained that federal courts must dismiss a case whenever they determine that they lack subject-matter jurisdiction, meaning the court lacks legal authority to decide the dispute. Patterson identified federal-question jurisdiction on the court’s complaint form but did not identify the federal constitutional, statutory, or treaty right at issue. The court’s review of the complaint did not reveal a federal-law claim. The allegations against Minfield might support state-law claims such as assault and battery, but they did not suggest that Minfield violated federal law.
The court also considered whether Patterson intended to assert a federal discrimination claim against Hennepin County. The court stated that this was unclear because the caption did not name the County. In addition, Patterson’s discrimination allegations were conclusory and lacked facts showing that race or another protected category caused the alleged mistreatment. The court therefore concluded that the complaint did not establish federal-question jurisdiction.
Ruling
The court dismissed the action without prejudice for lack of jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court also denied the application to proceed without prepaying fees or costs as moot. The order directed that judgment be entered accordingly.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.