Blackwell v. City of Saint Paul

Background

Richard Preston Blackwell alleged that he was subjected to an illegal search and seizure in September 2018. He sued the City of Saint Paul and Todd Axtell, Reginak, Chouinard, and Bjorkman under 42 U.S.C. § 1983, a federal civil-rights statute, and under state law.

Blackwell applied to proceed in forma pauperis, meaning without paying the filing fee. The court therefore screened his complaint under 28 U.S.C. § 1915(e)(2)(B) to determine whether it was frivolous, malicious, or failed to state a claim for relief. The court noted that his application contained at least one clear misstatement about earlier federal litigation and that he had filed at least eight other lawsuits in the District of Minnesota since 2023. The court also noted that one earlier lawsuit appeared substantively identical to this one, but the court did not rely on that earlier proceeding as the basis for the disposition here.

Federal Claims

The court held that Blackwell’s § 1983 claims were untimely. It explained that Minnesota’s six-year statute of limitations for personal-injury claims governs § 1983 claims in Minnesota. Because the alleged events occurred in September 2018 and Blackwell filed this action on March 20, 2025, the court concluded that the six-year period had expired.

The court determined that the § 1983 claims could not be successfully amended because nothing Blackwell could plead at that point would make them timely. It therefore dismissed those claims with prejudice.

State-Law Claims and Jurisdiction

The court stated that the state-law claims were likely untimely as well, but dismissed them for a different reason. Federal-question jurisdiction supported the § 1983 claims, but Blackwell did not allege diversity of citizenship, and the complaint appeared to indicate that every party was a Minnesota citizen. After dismissing the federal claims at the beginning of the case, the court declined to exercise supplemental jurisdiction over the remaining state-law claims.

The court dismissed the state-law claims without prejudice because of the lack of jurisdiction. A dismissal without prejudice does not itself bar refiling, although the court did not decide whether the state-law claims would be timely or otherwise viable.

Disposition

The court dismissed the matter under 28 U.S.C. § 1915(e)(2)(B) as follows:

- The § 1983 claims were dismissed with prejudice. - The state-law claims were dismissed without prejudice. - Blackwell’s application to proceed in forma pauperis was denied. - The court certified that an appeal could not be taken in good faith.

Judgment was ordered to be entered.