Sagataw v. Frey

Background

The case concerned several versions of a homeless encampment called Camp Nenookaasi, which occupied nine City-owned locations in Minneapolis between January 1, 2024, and January 6, 2025. The City cleared and closed the eighth location on November 12, 2024, and the ninth location burned down after multiple propane tanks exploded. The record showed that no centralized encampment called Camp Nenookaasi remained on Minneapolis property.

The ten named plaintiffs said they had been evicted from prior versions of the camp. They asked the court to certify a class under Federal Rule of Civil Procedure 23(b)(2), covering people who experienced an eviction from Camp Nenookaasi on one or more of four specified dates. For the proposed class, they sought an injunction preventing Mayor Jacob Frey and people working with him from evicting encampments in Minneapolis’s East Phillips neighborhood unless specified housing or temporary-relocation conditions were met.

The opinion noted that none of the four evictions listed in the proposed class definition occurred within East Phillips’s official boundaries. It also noted that the record did not show that any plaintiff currently lived in an East Phillips encampment.

Standing and jurisdiction

To seek an injunction, a plaintiff must have standing—the legal requirement that the plaintiff face an ongoing injury or a real and immediate threat of future injury that the requested order would address. The court concluded that the plaintiffs had not met that requirement. No record evidence showed that any plaintiff resided in an East Phillips encampment when the class-certification motion was filed or faced a certainly impending eviction there.

The court rejected the plaintiffs’ argument that their past Camp Nenookaasi evictions, together with the cyclical nature of homelessness, established standing for future injunctive relief. Past exposure to alleged unlawful conduct was not enough, and the possibility that a plaintiff might later live in an East Phillips encampment and face an eviction was too speculative.

Disposition

The court ordered that Plaintiffs’ Motion for Class Certification was DENIED. It also ordered that the Second Amended Complaint was DISMISSED WITHOUT PREJUDICE under Federal Rule of Civil Procedure 12(h)(3) for lack of subject-matter jurisdiction, but only to the extent it sought injunctive and prospective declaratory relief. The opinion did not state that the court reached the merits of the underlying eviction-related claims.