McNeil v. UnitedHealthcare Group Inc.
- Jeffrey Bryan
- 0:25-cv-02489
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In McNeil v. UnitedHealthcare, Judge Bryan dismissed plaintiff Alexander McNeil's complaint without prejudice for failing to move his case forward.
Plaintiffs in federal civil cases who fail to take active steps to move their lawsuits forward, and litigants who do not file objections to a Magistrate Judge's recommendations within the required time period.
What happened
In McNeil v. UnitedHealthcare Group Inc. (Case No. 25-cv-2489), plaintiff Alexander McNeil filed a lawsuit against UnitedHealthcare in the U.S. District Court for the District of Minnesota. A Magistrate Judge recommended that the case be dismissed because McNeil failed to take steps to prosecute — meaning he did not actively pursue — his case.
McNeil did not file any objections to that recommendation within the required time period. Under the rules governing federal court review, when no objections are filed, the district court only has to check for clear error in the Magistrate Judge's reasoning.
Judge Jeffrey M. Bryan adopted the Magistrate Judge's recommendation and found no error in it. The case was dismissed without prejudice, meaning McNeil is not automatically barred from refiling his claim in the future.
The detailed version
- McNeil v. UnitedHealthcare Group Inc. · No. 0:25-cv-02489
- Jeffrey M. Bryan
- Sept. 15, 2025
Note on Date Discrepancy
The opinion caption lists a filing date of 2025, but the signature block reads 'September 15, 2023.' This reviewer has used the filing date of September 15, 2025 consistent with the case metadata, as the 2023 date appears to be a typographical error in the opinion.
Background
Plaintiff Alexander McNeil filed a civil complaint against UnitedHealthcare in the District of Minnesota. The opinion does not describe the underlying claims or the nature of McNeil's dispute with UnitedHealthcare.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R&R) on August 12, 2025, recommending that McNeil's complaint be dismissed without prejudice under Federal Rule of Civil Procedure 41(b). Rule 41(b) authorizes a court to dismiss a case when a plaintiff fails to prosecute — that is, fails to take the necessary steps to move the case forward. The opinion does not elaborate on the specific conduct (or inaction) by McNeil that led to this recommendation.
Plaintiff's Response
McNeil did not file any objections to the R&R within the time permitted under District of Minnesota Local Rule 72.2(b)(1).
Standard of Review
When specific objections to an R&R are filed, the district court must conduct a de novo (fresh, independent) review of those portions. When no objections are filed, the district court reviews the R&R only for clear error. Because McNeil filed no objections, Judge Bryan applied the clear-error standard, citing 28 U.S.C. § 636(b)(1), Local Rule 72.2(b), and the Eighth Circuit's decision in Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996).
Ruling
Judge Bryan found no error — clear or otherwise — in Magistrate Judge Elkins's reasoning. The court adopted the R&R in full and dismissed the case without prejudice for failure to prosecute. A 'without prejudice' dismissal means the dismissal does not automatically bar McNeil from refiling his claims, though other legal constraints (such as statutes of limitations) could independently affect his ability to do so.
What the Opinion Does Not Address
The opinion does not describe the underlying legal claims, the nature of the dispute between McNeil and UnitedHealthcare, or the specific conduct that constituted failure to prosecute. It is a short procedural order adopting the R&R based on the absence of objections and absence of clear error.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.