Stefannie Dyson and Sean Wells-El v. Bartolomei

Background

Pro se plaintiffs Stefannie Dyson and Sean Wells-El filed this federal lawsuit arising from events in a Minnesota state criminal case against Rajuan M. Jones, who is Dyson's son. The relationship of Wells-El to the other parties is not explained in the opinion.

On May 23, 2025, Hennepin County District Court Judge Luis Bartolomei issued an order (the "May 23 Order") rejecting motions that Dyson had filed in Jones's criminal case despite not being a licensed attorney. The order directed court administration to summarily reject any future filings by non-parties, limiting filings to the Hennepin County Attorney's Office and Jones himself (who was self-represented). On May 29, 2025, Wells-El also attempted to file documents in the case and was turned away by the clerk's office pursuant to the May 23 Order. Jones himself sought a writ of mandamus (an order from a higher court compelling a lower court to take a specific action) from the Minnesota Court of Appeals, which denied the petition on June 25, 2025.

Plaintiffs filed this federal action on June 2, 2025, naming Judge Bartolomei, court administrator Sarah Lindahl-Pfieffer, Hennepin County District Court 4th District, and the State of Minnesota. The court characterized the complaint's claims as: (1) a 42 U.S.C. § 1983 civil rights claim for damages and injunctive relief against Judge Bartolomei and Lindahl-Pfieffer in both individual and official capacities; (2) a Monell claim (a theory of municipal liability under § 1983) against Hennepin County District Court 4th District; (3) a § 1983 claim against the State of Minnesota; and (4) state-law fraud and negligence claims against all defendants. Plaintiffs sought damages, vacatur of the May 23 Order, a federal court order directing acceptance of their filings, and reversal of Jones's criminal sentence.

Recusal Motion

Plaintiffs moved to recuse both the district judge and Magistrate Judge John F. Docherty. The basis for recusal was that the district court had previously dismissed a separate, unrelated lawsuit filed by Dyson's other child, Mark Rozell Jones, which concerned a child custody dispute.

The court denied recusal. Under 28 U.S.C. § 455(a) and (b)(1), recusal is required only if a judge's impartiality might reasonably be questioned or if the judge has a personal bias or prejudice concerning a party. Judges are presumed impartial, and the party seeking recusal bears a substantial burden. The court held that disagreement with a prior judicial ruling is not a sufficient basis for recusal under Liteky v. United States, 510 U.S. 540 (1994). The court further found that the prior case (involving a child custody dispute) and the present case (involving a criminal proceeding) were entirely unrelated, so no prior impressions existed. Plaintiffs' characterizations of prior conduct as "systematic deprivation of access to the courts" were deemed unsupported speculation insufficient to warrant recusal. Regarding Magistrate Judge Docherty, the court noted that the district judge — not the magistrate judge — was deciding the dispositive motion, making recusal of the magistrate judge unnecessary.

Motion to Dismiss — Jurisdictional Issues

Rooker-Feldman Doctrine

Defendants argued that the Rooker-Feldman doctrine barred the suit. This doctrine prevents federal district courts from reviewing state court judgments — only the U.S. Supreme Court may review state court decisions. The court declined to apply it here because the doctrine applies only to "state-court losers" who were parties to the underlying state proceeding. Dyson and Wells-El were not parties to Jones's criminal case; only Jones was. Accordingly, the court found Rooker-Feldman inapplicable.

Eleventh Amendment Sovereign Immunity — State of Minnesota

The Eleventh Amendment to the U.S. Constitution bars private parties from suing a state in federal court, whether for damages or injunctive relief. The court found that neither exception to this immunity applied: Congress has not abrogated (overridden) Eleventh Amendment immunity for § 1983 claims, and the State of Minnesota has not consented to be sued under § 1983. The court also held that Eleventh Amendment immunity extends to pendant state law claims based on the same underlying conduct. Notably, plaintiffs did not oppose defendants' sovereign immunity argument, which the court treated as forfeiture of those claims. All claims against the State of Minnesota were therefore dismissed.

Younger Abstention

The court declined to address Younger abstention (a doctrine under which federal courts sometimes refrain from interfering with ongoing state proceedings), noting it is not a true jurisdictional doctrine and that other grounds for dismissal existed.

Motion to Dismiss — Merits Issues

Monell Claim Against Hennepin County District Court and Official-Capacity Damages Claims

Under Monell v. Department of Social Services, 436 U.S. 658 (1978), a municipality cannot be held liable under § 1983 merely because it employs someone who violated constitutional rights. Liability requires proof of: (1) an official municipal policy; (2) an unofficial widespread custom; or (3) deliberate indifference in failing to train or supervise.

The court rejected all three theories. As to official policy, plaintiffs did not identify any specific policy permitting unlawful censorship, and the May 23 Order itself could not constitute official policy because Judge Bartolomei lacked final policymaking authority — the order could be reversed by higher state courts. As to unofficial custom, plaintiffs described only a single incident (the May 23 Order), which is legally insufficient to establish a widespread and persistent pattern of unconstitutional misconduct. As to failure to train, plaintiffs offered only a bare legal conclusion with no supporting factual allegations, which is insufficient under Ashcroft v. Iqbal, 556 U.S. 662 (2009).

Judicial Immunity — Section 1983 Damages Claim Against Judge Bartolomei Individually

Judicial immunity shields judges from suit — not merely from liability — for their judicial acts, including § 1983 civil rights claims. Two narrow exceptions exist: (1) non-judicial actions; and (2) actions taken in the complete absence of all jurisdiction.

The court found neither exception applicable. Issuing the May 23 Order was a core judicial act — resolving a dispute over who could file in a pending case — performed in the course of a criminal proceeding over which the state district court had original jurisdiction under Minnesota law. The court rejected plaintiffs' argument that the May 23 Order was an administrative act under Forrester v. White, 484 U.S. 219 (1988), distinguishing that case (which involved personnel decisions like firing a court employee) from the quintessentially judicial act of managing filings in a pending proceeding. The § 1983 damages claim against Judge Bartolomei in his individual capacity was dismissed.

Quasi-Judicial Immunity — Section 1983 Damages Claim Against Lindahl-Pfieffer Individually

Court clerks receive absolute quasi-judicial immunity for acts taken at the direction of a judge or according to court rules. Lindahl-Pfieffer's rejection of Wells-El's filings was done in direct compliance with the May 23 Order. The court rejected plaintiffs' arguments that the conduct was criminal (not alleged in the complaint and speculative) and that Antoine v. Byers & Anderson, Inc., 508 U.S. 429 (1993), applied (that case addressed court reporters, not court clerks). The § 1983 damages claim against Lindahl-Pfieffer in her individual capacity was dismissed.

Section 1983 Claims for Injunctive Relief

The court dismissed all § 1983 injunctive relief claims on multiple grounds:

- Individual-capacity injunctive relief against both Judge Bartolomei and Lindahl-Pfieffer failed because neither individual has authority in their personal capacity to grant the relief sought (accepting filings, holding hearings, reversing a criminal sentence). - Official-capacity injunctive relief against Judge Bartolomei failed because judicial immunity also bars claims for prospective injunctive relief against judicial officials acting in their judicial capacity, per Justice Network Inc. v. Craighead County, 931 F.3d 753 (8th Cir. 2019). - Official-capacity injunctive relief against Lindahl-Pfieffer: While the Ex parte Young doctrine generally permits injunctive relief against state officers without violating sovereign immunity, the Supreme Court has recognized it does not normally permit federal courts to issue injunctions against state court judges or clerks. The court applied this principle to Lindahl-Pfieffer as a state court clerk.

Because all § 1983 claims were dismissed, a § 1983 conspiracy claim (which requires proving an underlying constitutional deprivation) also necessarily failed.

Other Federal Statutes

Plaintiffs referenced the Tucker Act, the Administrative Procedure Act, and the Privacy Act, but the complaint contained no factual allegations supporting liability under any of those statutes. Those claims were dismissed. The court also declined to consider an Equal Protection Clause argument raised for the first time in opposition briefing, as a complaint cannot be amended through briefs.

State-Law Claims

Having dismissed all federal claims, the court declined to exercise supplemental jurisdiction (the authority to hear related state law claims alongside federal claims) over the remaining state-law fraud and negligence claims. Those claims were dismissed without prejudice so that they may be pursued, if at all, in Minnesota state courts.

Procedural Note

Plaintiffs filed an unauthorized sur-reply after briefing closed. The court declined to consider it as neither the Local Rules nor any court order authorized such a filing. The court also rejected plaintiffs' due process objection to the absence of an oral hearing, noting that the Local Rules permit deciding dispositive motions on the papers.

Disposition

Plaintiffs' Motion for Recusal was denied. Defendants' Motion to Dismiss was granted. The entire complaint was dismissed without prejudice.