Edner v. Redwood County District Attorney's Office
- Susan Nelson
- 0:19-cv-02486
- U.S. District Court · District of Minnesota
- 32
Counsel of record per CourtListener. Firm names are approximate.
In Edner v. Redwood County District Attorney's Office, Judge Nelson dismissed most defendants from pro se plaintiff Ryan Edner's civil-rights lawsuit, allowing claims against only two law enforcement officers to proceed.
People who file civil-rights lawsuits (under 42 U.S.C. § 1983) against government officials, prosecutors, judges, defense attorneys, and police arising from criminal prosecutions. The opinion illustrates the significant immunity doctrines protecting prosecutors and judges, the limits on suing public defenders under § 1983, the requirements for supervisory liability, and the pleading standards for conspiracy claims in civil-rights cases.
What happened
In Edner v. Redwood County District Attorney's Office (No. 19-CV-2486), Ryan C. Edner, representing himself, sued 25 defendants — including prosecutors, a judge, court staff, law enforcement officers, and defense attorneys — over his decade-long state criminal proceedings in Redwood County, Minnesota, which ended when the State dismissed the charges in 2024 because the marijuana evidence had degraded beyond measurable levels. Edner alleged violations of federal criminal statutes and a broad civil conspiracy to deprive him of his constitutional rights under 42 U.S.C. § 1983, the federal civil-rights law that allows lawsuits against state and local officials for constitutional violations.
The court reviewed the complaint under its authority to screen cases filed by people who cannot afford court fees, assessing whether each claim had a plausible legal basis. It found that: the federal criminal statutes Edner cited (18 U.S.C. §§ 242 and 1951) do not allow private lawsuits; the prosecutor defendants are shielded by absolute prosecutorial immunity for actions taken while pursuing the case; Judge Rohland is protected by absolute judicial immunity; the court clerk and court reporter claims lacked factual support; the defense attorneys (public and private) are not state actors subject to the civil-rights law; the Minnesota State Board of Public Defense has sovereign immunity as a state entity; police departments and sheriff's departments are not legally recognized entities that can be sued; the supervisory officers (Sheriff Hanson and Chief Deputy Farasyn) were not plausibly alleged to have directly participated or failed to train subordinates; and the remaining named deputies and a Breckenridge officer faced only conclusory allegations.
United States District Judge Susan Richard Nelson declined to adopt Magistrate Judge Leo I. Brisbois's recommendation to dismiss the entire case for failure to prosecute, finding that Edner's objection itself showed intent to pursue the case. The court also denied Edner's request for a further stay of proceedings. Ultimately, Judge Nelson dismissed 23 of the 25 defendants without prejudice under 28 U.S.C. § 1915(e)(2), meaning Edner is not currently barred from attempting to refile, but allowed the claims against two defendants — Investigator Jason Jacobson of the Redwood County Sheriff's Department and Police Chief Bostyn Thompson of the City of Morgan Police Department — to proceed to the next stage.
The detailed version
- Edner v. Redwood County District Attorney's Office · No. 0:19-cv-02486
- Susan Nelson
- Aug. 20, 2025
Background
Ryan C. Edner, proceeding without an attorney (pro se) and without paying the filing fee (seeking "in forma pauperis" or IFP status), filed this federal civil-rights lawsuit in 2019 against 25 defendants connected to his state criminal proceedings in Redwood County, Minnesota. Those proceedings began in September 2015 when law enforcement executed search warrants at the Edner residence and discovered drug paraphernalia, marijuana, firearms, and related items. Edner was charged with drug possession, weapons offenses, and related crimes. The state case stretched nearly a decade, involving multiple defense attorneys, repeated continuances, competency evaluations, failures to appear, and multiple arrest warrants. Ultimately, the State dismissed the charges in 2024 because THC in the physical evidence had degraded below reportable levels.
Edner had previously initiated this federal lawsuit while the state case was pending. The district court initially dismissed it without prejudice under the Younger abstention doctrine — a principle requiring federal courts to refrain from interfering with ongoing state criminal proceedings. The Eighth Circuit affirmed the abstention but vacated the dismissal as to Edner's damages claim and remanded for a stay. After the state charges were dismissed, Magistrate Judge Leo I. Brisbois ordered Edner to notify the court of his intent to prosecute within 30 days. Edner did not respond, and Magistrate Judge Brisbois issued a Report and Recommendation (R&R) recommending dismissal for failure to prosecute under Federal Rule of Civil Procedure 41(b). Edner then filed a timely objection, conceding his noncompliance but expressing intent to proceed.
Procedural Rulings
Objection to the R&R
Judge Nelson declined to adopt Magistrate Judge Brisbois's R&R recommending dismissal for failure to prosecute. The court acknowledged that Edner failed to comply with the magistrate judge's order and that a district court has discretion to dismiss for such noncompliance. However, the court found that Edner's objection itself clearly demonstrated an intent to prosecute. The court was not persuaded that overlapping filing deadlines constituted good cause for the noncompliance, but exercised its discretion not to dismiss on that ground.
Request for Stay
Edner also requested a further stay of proceedings under the Younger abstention doctrine, citing ongoing appellate proceedings including a petition for a writ of certiorari (a request for the U.S. Supreme Court to hear a case). The court denied this request. Public court records confirmed the state criminal charges had been dismissed, no notice of appeal in that case was found, and the court noted that the certiorari petition concerned a different case file entirely.
Preservice Review Under 28 U.S.C. § 1915(e)
Because Edner sought IFP status, the court was required to screen his complaint before allowing service on defendants. Under 28 U.S.C. § 1915(e)(2), a court must dismiss a complaint that is frivolous, malicious, or fails to state a claim on which relief can be granted. The court applied the standard from Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, requiring that factual allegations be sufficient to raise a plausible right to relief — not merely legal conclusions dressed as facts.
Claims Under 18 U.S.C. §§ 242 and 1951
Edner asserted violations of two federal criminal statutes: 18 U.S.C. § 242 (deprivation of rights under color of law) and 18 U.S.C. § 1951 (interference with commerce by threats or violence, commonly known as the Hobbs Act). The court dismissed both claims because neither statute creates a private right of action — only the federal government, through the Executive Branch, can prosecute violations of these criminal laws. Private citizens cannot sue under them.
Claims Under 42 U.S.C. § 1983
Edner's primary civil claim was a conspiracy to violate his constitutional rights under 42 U.S.C. § 1983, which allows private lawsuits against state and local officials who violate constitutional rights while acting under color of state law. The court analyzed each category of defendants separately.
Category One: Prosecutors
The prosecutor defendants — the Redwood County District Attorney's Office, and Assistant County Attorneys Steven Collins, Jenna Peterson-Haler, and Kelly Meehan — were found to be entitled to absolute prosecutorial immunity. Prosecutors acting as advocates in criminal proceedings are absolutely immune from civil suit for conduct intimately associated with the judicial process, including initiating charges, making arguments in court, requesting continuances, and even the alleged knowing use of false testimony or suppression of exculpatory evidence. The court found that Edner's conspiracy allegations against the prosecutors were wholly conclusory — he offered no specific facts showing prosecutors entered into an agreement with law enforcement or defense attorneys to violate his rights. These defendants were dismissed.
Category Two: Judicial Officials
Redwood County District Courthouse
Dismissed because a courthouse building is not a legal "person" subject to suit under § 1983.
Judge Patrick Rohland
Dismissed under absolute judicial immunity. Judges are immune from suit for actions taken in their judicial capacity, even if those actions were erroneous or allegedly malicious, unless they acted in complete absence of jurisdiction. All of Edner's complaints about Judge Rohland — failing to rule on motions, granting continuances, allowing a warrant to be used — concerned his normal judicial functions. Conspiracy allegations did not defeat this immunity.
Patricia Amberg (Court Administrator)
Dismissed for failure to state a plausible claim. Edner's only allegation was a conclusory assertion that she conspired with Judge Rohland to deprive him of rights. No specific facts described what Amberg did or failed to do. Under § 1983, each defendant must be alleged to have personally violated constitutional rights; vicarious liability does not apply.
Jodi Haen (Court Reporter)
Dismissed as frivolous. Court reporters do not have absolute quasi-judicial immunity, but Edner's claim — that Haen charged for transcripts that were incomplete or inaccurate — was dismissed because Edner alleged no facts showing how any transcript deficiency actually violated his constitutional rights or affected the outcome of proceedings.
Category Four: Defense Attorneys
All defense attorney defendants — both public defenders (Joel Solie, Erica Allex) and private attorneys (Eric Olson, Ryan Garry, Paul Hunt, Megan Burkehammer) — were dismissed. Defense attorneys, whether public or private, are not state actors under color of state law for purposes of § 1983. The Supreme Court established in Polk County v. Dodson that even public defenders do not act under color of state law when performing traditional attorney functions. While private parties can be liable for conspiring with state actors under § 1983, the court found that Edner's conspiracy allegations were entirely conclusory. He identified no specific facts showing a "meeting of the minds" between defense attorneys and state officials about an unlawful objective.
Minnesota State Board of Public Defense
Dismissed on sovereign immunity grounds. As a state entity, it is immune from suit for any kind of relief under the Eleventh Amendment.
Category Three: Law Enforcement
Redwood County Sheriff's Department and City of Morgan Police Department
Dismissed because police and sheriff's departments are generally not legally recognized entities subject to suit under § 1983.
Sheriff Randy Hanson and Chief Deputy Mark E. Farasyn
Dismissed. Edner sued them on a supervisory liability theory, but § 1983 does not permit vicarious liability. Supervisors can only be liable if they directly participated in the constitutional violation or if their failure to train or supervise caused the deprivation. Edner alleged neither; he did not claim these supervisors personally ordered misconduct or that there was a known pattern of similar unconstitutional conduct by subordinates.
Deputies Mitch Zimmerman, Mike Campbell, Mike Hubin; Officer Kris Karlgaard (Breckenridge)
Dismissed for failure to state a plausible claim. Allegations against Zimmerman, Campbell, and Hubin (conspiracy to falsify reports, failure to investigate, failure to report misconduct) were conclusory, lacking specific facts. As for Karlgaard, Edner's sole allegation was that Jacobson directed Karlgaard to threaten Edner's grandmother with a fraudulent arrest warrant. The court found: (1) Edner cannot bring claims on his grandmother's behalf while representing himself; and (2) verbal threats alone are not actionable under § 1983.
Jason Jacobson (Redwood County Sheriff's Department) and Bostyn Thompson (City of Morgan Police Department)
The court allowed these claims to proceed past initial screening. The court expressed skepticism about the claims and noted the state court record may ultimately dispose of them, but declined to dismiss at this stage without access to the pertinent records. The court cautioned Edner that this screening does not preclude the defendants from later filing motions to dismiss under Rule 12(b)(6).
Disposition
Judge Nelson:
- Declined to adopt Magistrate Judge Brisbois's R&R.
- Denied Edner's request for a further stay.
- Dismissed without prejudice 23 of the 25 named defendants under 28 U.S.C. § 1915(e)(2).
- Allowed claims against Jason Jacobson and Bostyn Thompson to proceed.
Read the full 32-page opinion on CourtListener, the free public archive maintained by the Free Law Project.