Guertin v. Walz
- Paul Magnuson
- 0:25-cv-02670
- U.S. District Court · District of Minnesota
- 6
Counsel of record per CourtListener. Firm names are approximate.
In Guertin v. Walz, Judge Magnuson dismissed the action without prejudice, denied two motions as moot, and found an appeal could not be taken in good faith.
Matthew D. Guertin and the defendants named in his federal action. The dismissal ended this federal case without prejudice, and the order also resolved Guertin’s two motions as moot.
What happened
In Guertin v. Walz, Matthew D. Guertin filed a federal lawsuit challenging his ongoing state criminal proceedings and alleging that officials and others had created a false version of the legal proceedings. The complaint was more than 120 pages long and included dozens of additional claims.
The court identified several problems. It found that the complaint was not a short and clear statement as required by the federal rules. It also concluded that federal courts could not provide relief that would interfere with the ongoing state case, that many defendants had immunity from the claims, that some criminal laws did not allow private lawsuits, and that the complaint was based on facts the court considered wholly incredible.
Judge Magnuson dismissed the action without prejudice. He denied as moot Guertin’s request for the U.S. Marshal to serve the defendants and his request to disqualify Judge Jerry W. Blackwell. The court also stated that an appeal could not be taken in good faith.
The detailed version
- Guertin v. Walz · No. 0:25-cv-02670
- Paul Magnuson
- July 10, 2025
Background
Matthew D. Guertin was charged in state court with various gun offenses in 2023. The opinion states that the state case has progressed slowly because Guertin has repeatedly been found unable to assist in his own defense. Guertin had previously filed a federal lawsuit challenging aspects of that prosecution, but the earlier action was dismissed without prejudice under the Younger abstention doctrine. That doctrine generally prevents a federal court from interfering with an ongoing state criminal proceeding.
Guertin filed this new federal complaint against numerous people and entities, including state and county officials, judges, court employees, attorneys, public defenders, and psychologists. The complaint was more than 120 pages long and contained 540 paragraphs. Its central allegation was that Guertin was the only real human defendant in an otherwise artificial legal system, with fictitious documents obscuring what was happening in the state case. The complaint also asserted many additional challenges to the way the prosecution had been conducted.
Court’s Reasons
The court identified several independent problems with the complaint:
- Failure to meet the pleading rule: Federal Rule of Civil Procedure 8(a)(2) requires a complaint to give a short and plain statement showing why the plaintiff is entitled to relief. The court found that Guertin’s complaint was neither short nor plain. - Interference with the state case: The court held that the Younger abstention doctrine remained a barrier to obtaining federal relief from the ongoing state criminal prosecution. - Immunity: The court stated that most of the individual defendants had either judicial or prosecutorial immunity from suit. Judicial immunity generally protects judges from lawsuits based on their judicial acts, while prosecutorial immunity can protect prosecutors for covered prosecutorial conduct. - Claims based on criminal statutes: The court stated that the complaint repeatedly relied on criminal statutes that do not create a private right to sue. It concluded that Guertin lacked standing to bring claims under those provisions, creating a jurisdictional problem. - Frivolous factual allegations: The court described the complaint’s foundational allegation as delusional and found that the complaint was based on facts that were “wholly incredible.” It therefore characterized the lawsuit as frivolous.
The court noted that any one of these problems could allow a federal court to act on its own without waiting for a defendant to raise the issue. Although the court said it would have allowed Guertin to amend the complaint if excessive length and complexity were the only defects, it found that the additional problems required dismissal.
Disposition
The court ordered that the action be dismissed without prejudice. It denied as moot Guertin’s motion for service of process by the U.S. Marshal under 28 U.S.C. § 1915(d). It also denied as moot Guertin’s motion to disqualify Judge Jerry W. Blackwell because Judge Blackwell had recused himself from the matter.
The court further stated that an appeal could not be taken from the dismissal in good faith and that any application by Guertin to appeal without paying filing fees would be denied on that basis.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.