Quinlan v. Puls

Background

Carsten J. Quinlan sued his former spouse, Daniel Puls, and his former spouse’s parents, Cheryl Puls and Alissa Puls. Quinlan represented himself. His second amended complaint asserted federal constitutional claims and state-law claims, including defamation, fraud, malicious prosecution, and breach of contract. He also applied to proceed in forma pauperis, meaning without paying certain litigation costs, and sought a temporary restraining order to prevent alleged harassment, stalking, monitoring, and interference with his legal rights.

Because Quinlan applied for this status, the court reviewed his pleading under 28 U.S.C. § 1915(e)(2)(B). The court was required to accept factual allegations as true at this stage and read the self-represented pleading liberally, but the complaint still had to state a plausible claim for relief.

Federal-law claims

Quinlan alleged that the defendants violated his due-process rights by providing false information to authorities and others, causing state action affecting his parenting time and medical authority. He also alleged that his former spouse violated his First Amendment rights through threats and statements to authorities. These claims were brought under 42 U.S.C. § 1983.

The court explained that § 1983 generally permits claims only against state actors—people acting for the state. Quinlan did not allege that any defendant was a state employee or agent. The court rejected his argument that reporting information to authorities, filing police reports, or giving testimony automatically made the private defendants state actors. Quinlan did not plausibly allege that state actors delegated a state function to the defendants or that the defendants acted sufficiently in concert with state actors.

Quinlan also alleged a conspiracy claim that the court interpreted as potentially arising under 42 U.S.C. § 1985. The court concluded that he did not allege a conspiracy involving a federal-government function, interference with testimony or a legal proceeding, obstruction of justice, or class-based discriminatory motivation. The court therefore found no viable federal claim.

State-law claims and jurisdiction

The court stated that the state-law claims could be heard through diversity jurisdiction only if the parties were citizens of different states and more than $75,000 was at stake. Complete diversity requires every plaintiff to be a citizen of a different state from every defendant.

Quinlan alleged that he resided in Minnesota; that Cheryl Puls and Daniel Puls resided in Wisconsin; and that Alissa Puls resided in either Minnesota or Wisconsin. The court held that the word “either” left open the possibility that Alissa Puls was a Minnesota citizen, which meant Quinlan had not adequately pleaded complete diversity. The court also declined to exercise supplemental jurisdiction over the state-law claims after dismissing the federal claims.

Other rulings

The court adopted the April 7, 2025 Report and Recommendation of Magistrate Judge Douglas L. Micko concerning Quinlan’s request for a temporary restraining order. The court agreed that Quinlan had not shown imminent irreparable harm. It also stated that he could not obtain preliminary injunctive relief because the claims over which the court had jurisdiction were being dismissed with prejudice and therefore had no chance of success.

Disposition

Judge Ann D. Montgomery ordered that all federal-law claims be dismissed with prejudice under 28 U.S.C. § 1915(e)(2)(B). She ordered that all state-law claims be dismissed without prejudice for lack of subject-matter jurisdiction. The court denied Quinlan’s application to proceed in forma pauperis, adopted the Report and Recommendation, and denied the motion for a temporary restraining order. The order states that the action was dismissed in its entirety.