Alvar v. State of Minnesota

Background

Ryan W. Alvar is a plaintiff involved in ongoing state court child-custody and child-support proceedings in Minnesota and Wisconsin. He filed a federal lawsuit against a large group of defendants, including state court judges, a referee, a child support magistrate, a guardian ad litem, several law firms and individual attorneys, county agencies, nonprofit organizations, and individual named persons. Earlier in the case, on October 14, 2025, the district court denied Mr. Alvar's motion for preliminary injunctive relief, dismissed his claims for declaratory and injunctive relief without prejudice (meaning he could potentially refile), and stayed (paused) his damages claims. That ruling was based on Younger v. Harris, 401 U.S. 37 (1971), a doctrine under which federal courts generally decline to interfere with ongoing state court proceedings.

The November 6, 2025 order addresses three separate motions filed by Mr. Alvar after the October 14th ruling.

Motion for Reconsideration of the October 14th Order

Mr. Alvar asked the court to vacate the portion of the October 14th Order applying Younger abstention and to rule on a pending motion to seal. Under the District of Minnesota's Local Rule 7.1(j), a party must first obtain the court's permission to file a motion for reconsideration and must show "compelling circumstances" — meaning either a manifest (obvious) error of law or fact, or newly discovered evidence.

The court found that Mr. Alvar identified no newly discovered evidence and pointed to no manifest error of law or fact in the October 14th Order. Accordingly, the motion for reconsideration (Dkt. 67) was denied.

Appeal/Objection to Magistrate Judge's Sealing Orders

Background on the Sealing Dispute

When Mr. Alvar originally filed his case and sought emergency injunctive relief, he attached as Exhibit F a guardian ad litem family court report prepared by defendant Jordan Mae Dokken. The state court had previously declared that report confidential and had ordered Mr. Alvar to remove it from advocacy websites and refrain from publicly disclosing it. The State Defendants moved to have the federal court docket entry sealed. On October 22, 2025, Magistrate Judge Leo I. Brisbois granted that motion (the "October 22nd Order"). Mr. Alvar moved for reconsideration, which Judge Brisbois denied on October 24, 2025 (the "October 24th Order").

Mr. Alvar then objected to the October 24th Order under Federal Rule of Civil Procedure 72 and District of Minnesota Local Rule 72.2(a), which allow a district judge to review a magistrate judge's ruling on non-dispositive (non-case-ending) matters.

Standard of Review

For non-dispositive orders, the standard is "extremely deferential": the order is reversed only if it is "clearly erroneous or contrary to law." Clear error exists when the reviewing court has "the definite and firm conviction that a mistake has been committed." A decision is contrary to law when it "fails to apply or misapplies relevant statutes, case law or rules of procedure."

Court's Analysis

Mr. Alvar raised several arguments:

1. Conflict between the October 22nd and October 24th Orders. Mr. Alvar pointed to a typographical error in the October 22nd Order's third numbered paragraph, which directed him to file a "redacted version" of the guardian ad litem report — which appeared to conflict with the overall directive to remove it entirely. The court found that Judge Brisbois's October 24th Order had already clarified the correct instruction: Mr. Alvar was to file a public version of Docket No. 6 with Exhibit F (the guardian ad litem report) removed entirely, while redacting personal identifying information from the remaining exhibits. The court found no genuine conflict.

2. Failure to provide findings or hearing as required by Press-Enterprise. Mr. Alvar argued that the sealing order required specific findings and a hearing under Press-Enterprise Co. v. Superior Court, 464 U.S. 501 (1984). The court rejected this argument, explaining that Press-Enterprise concerned the presumption of openness in criminal trials and whether the press and public can be barred from a criminal proceeding. This case is a civil matter, and the governing standards for sealing documents in civil federal court were properly applied by Judge Brisbois, who also fully explained his reasoning.

3. Remaining contentions. Mr. Alvar also argued that the sealing remedy was not "narrowly tailored" in violation of the First Amendment, that his motion had been mischaracterized as reargument rather than a compliance request, and that Judge Brisbois expanded the sealing to additional filings without a motion or analysis. The court found these contentions lacked merit.

The court affirmed both the October 22nd Order (Dkt. 70) and the October 24th Order (Dkt. 78), and denied the Appeal/Objection (Dkt. 81).

Motion for Temporary Restraining Order Regarding Child-Support Enforcement

Background

Mr. Alvar faces a series of child-support enforcement actions initiated by St. Louis County and state agencies. These include: a claim to collect past-due payments with tax refund offsets; reporting of arrears to credit bureaus; potential suspension of his driver's license; potential suspension of occupational and professional licenses; and other enforcement mechanisms. By September 2025, his unpaid balance exceeded $11,000. On October 20, 2025, the Minnesota Department of Public Safety notified him that his driver's license would be suspended effective November 7, 2025. Mr. Alvar stated that at a September 4, 2025 state court hearing, Judge Nicole Hopps acknowledged that the child-support portion of his case needed to be reopened, but no order had been issued.

Mr. Alvar moved for a temporary restraining order (a short-term emergency court order) asking the federal court to prohibit the Minnesota Department of Human Services, St. Louis County Social Services, and the Department of Public Safety from: suspending his driver's or professional licenses; reporting arrears to credit bureaus; and collecting through revenue recapture, tax refund intercept, or other enforcement mechanisms.

He argued that he was likely to succeed on the merits because enforcement of an order "the state itself has deemed defective" violates due process, and that harm to his credit and license status cannot be undone by later payment or a court order.

Court's Ruling

The court denied the motion. It found that Mr. Alvar failed to demonstrate a likelihood of success on the merits of any claim in his Complaint — the threshold requirement for emergency injunctive relief. The court reiterated that, under the Younger abstention doctrine, it declines to exercise jurisdiction over his claims for injunctive relief while his state court proceedings remain ongoing. The court further noted that Mr. Alvar's assertion that a state court judge acknowledged the child-support case needed to be reopened does not establish that he lacks recourse through the state courts, and his unsupported claim that "the state itself has deemed [the child-support order] defective" had no evidentiary support in the record. The motion for a temporary restraining order (Dkt. 84) was denied.

Case Management Directive

The court noted that despite the stay of proceedings, Mr. Alvar continues to file requests for federal court intervention. Because the case remains stayed pending completion of state court proceedings, the court directed that defendants are under no obligation to respond to future filings by Mr. Alvar unless the court specifically instructs them to do so.