Macon v. State of Minnesota

Background

Brandon D Macon named three defendants: the State of Minnesota, the Minnesota Department of Human Services, and the Hennepin County Child Support Office. The opinion describes claims alleging that the Hennepin County office failed to identify or protect Macon despite signs that he was a vulnerable minor, maintained false or inaccurate records, refused to correct them, and imposed obligations without verification, investigation, or due process. The opinion also refers to allegations that Macon was homeless as a teenager in Minnesota and later suffered a serious stroke, although it does not state when the stroke occurred.

Subject-Matter Jurisdiction

The court held that sovereign immunity barred Macon’s claims against Minnesota and the Minnesota Department of Human Services. Sovereign immunity generally prevents a state and its agencies from being sued in federal court without a waiver. The court noted that Macon did not seek prospective injunctive relief against either defendant. The court therefore dismissed the claims against Minnesota and the Minnesota Department of Human Services without prejudice for lack of subject-matter jurisdiction and ordered that both defendants be terminated from the case.

The court concluded that it had subject-matter jurisdiction over the claims against the Hennepin County Child Support Office because that office appeared to be part of local or municipal government rather than the state. The court did not decide whether the office was legally capable of being sued because it transferred the remaining claims.

Venue and Disposition

The court found that venue was improper in the District of Arizona. It reasoned that the remaining defendant was a Hennepin County office, the alleged events occurred in Minnesota, and the relevant records were presumably created and maintained there. The court rejected the argument that Arizona was a proper venue merely because Macon allegedly experienced the effects of the defendants’ conduct there.

Under 28 U.S.C. § 1406(a), a court may transfer a case filed in the wrong district when transfer serves the interests of justice. The court found that the action could have been brought in the District of Minnesota and that transfer there was in the interest of justice. It ordered the clerk to transfer the action to the United States District Court for the District of Minnesota, Fourth Division, and to close the Arizona case. Judge Michael T. Liburdi did not rule on the merits of the underlying constitutional or other claims.