Quinlan v. Washington County

Background

Carsten J. Quinlan and Alissa Puls are the parents of three minor children. After a teacher reported that one child had engaged in inappropriate touching, Kim Richardson, a detective employed by the City of Woodbury, and Hailey Dornfeld, a Washington County Child Protective Services investigator, investigated. The child gave statements during a forensic interview describing sexual conduct involving Quinlan. Quinlan was prohibited from seeing his children during the investigation, was later arrested, and was charged with criminal sexual conduct. A jury found him not guilty on April 8, 2024.

Quinlan filed this lawsuit against Washington County, the City of Woodbury, Richardson, and Dornfeld. His amended complaint asserted thirteen counts under state and federal law, including fraud, malicious prosecution, emotional-distress, abuse-of-process, defamation, negligence, wrongful arrest under 42 U.S.C. § 1983, due-process and family-rights violations, equal protection, vicarious liability, and ratification. He sought damages and injunctive relief. The defendants moved to dismiss, and Quinlan moved for permission to file a second amended complaint. Quinlan and the City Defendants also filed opposing motions for sanctions under Rule 11.

Claims Brought for the Minor Children

The court held that Quinlan could represent only himself because he was not a lawyer. It dismissed without prejudice all claims he purported to bring on behalf of his minor children. The court did not decide the merits of those children’s claims.

Federal Claims

The court treated the federal claims under the standard for a Rule 12(b)(6) motion, which asks whether the complaint alleges enough facts to state a legally plausible claim. On the due-process and family-rights claim, the court rejected both the substantive and procedural theories. It concluded that the alleged investigative failures did not plausibly show conduct that was sufficiently egregious to violate substantive due process. It also concluded that Quinlan had adequate opportunities to challenge the loss of contact with his children through criminal, child-protection, and protection-order proceedings. Count X was dismissed.

The court dismissed the equal-protection claim in Count XI because Quinlan challenged investigative decisions under a “class-of-one” theory, and the court held that such investigative decisions cannot be challenged under that theory. The court also dismissed the wrongful-arrest claim in Count IX. Based on the child’s forensic-interview statements and other information available to Richardson, the court found probable cause, or at least objectively reasonable “arguable probable cause,” for the arrest. Quinlan’s later acquittal did not establish that probable cause was absent when he was arrested.

The court dismissed the malicious-prosecution claim in Count II because Quinlan offered only conclusory allegations that Richardson and Dornfeld used fabricated evidence or acted maliciously. The court found that the child’s statements gave Richardson a reasonable basis to believe that Quinlan had committed the charged offense.

State-Law Claims

The court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims after the federal claims providing original jurisdiction have been dismissed—over Counts I, III through VIII, XII, and XIII. Those claims were dismissed without prejudice. The opinion therefore did not resolve their merits.

Motion to Amend

The court denied Quinlan’s motion for permission to file a second amended complaint. It found the proposed amendment futile because the proposed claims would not survive a motion to dismiss. The court also stated that proposed § 1983 claims against Alissa Puls were not viable because she was a private individual and Quinlan had not plausibly alleged that she acted under color of state law.

Motions for Sanctions and Disposition

The court denied both sides’ Rule 11 sanctions motions. Although it found that some of Quinlan’s proposed claims lacked support, it concluded that his filings did not amount to objectively unreasonable or sanctionable conduct, particularly in light of his status as a self-represented litigant. The court granted the City Defendants’ motion to dismiss and the County Defendants’ motion to dismiss, denied the motion to amend, denied both sanctions motions, and directed that judgment be entered accordingly.