Edner v. Jacobson

Background

Pro se (self-represented) plaintiff Ryan C. Edner brought this civil action against Jason Jacobson of the Redwood County Sheriff's Department and Bostyn Thompson of the City of Morgan Police Department. The case has a connection to an underlying state criminal matter, State of Minnesota v. Edner, No. 64-CR-15-649, in which certain court records are sealed.

Magistrate Judge Leo I. Brisbois issued an Order on January 20, 2026, ruling on two motions: (1) Edner's Motion to Enter a Protective Order, which was granted in part and denied in part; and (2) the Defendants' Motion to Extend Time to Answer or Otherwise Respond to Plaintiff's Complaint, which was granted. The extension tied the defendants' response deadline to twenty-one days after the state court issued its ruling on the defendants' separate request to access sealed state court records from Edner's criminal case.

Edner filed objections to the magistrate judge's order on January 27, 2026. Defendants opposed those objections.

Legal Standard

Because the magistrate judge's rulings were non-dispositive — meaning they did not terminate any claims or the case itself — the district court reviews them under a highly deferential standard. Under 28 U.S.C. § 636(b)(1)(A), Federal Rule of Civil Procedure 72(a), and Local Rule 72.2, a district court may set aside a magistrate judge's non-dispositive ruling only if it is "clearly erroneous or contrary to law." A ruling is "clearly erroneous" only if the reviewing court is left with a "definite and firm conviction that a mistake has been committed." A ruling is "contrary to law" if it "fails to apply or misapplies relevant statutes, case law or rules of procedure."

Edner's Three Objections and the Court's Rulings

Objection 1: Extension of Defendants' Deadline to Answer

Edner objected that tying the defendants' response deadline to an uncertain future state court decision created an open-ended risk of indefinite delay. However, after Edner filed his objections on January 27, 2026, the state court issued its decision on January 29, 2026. Under the terms of the magistrate judge's order, the defendants' response became due twenty-one days after that ruling. The defendants subsequently filed a motion to dismiss the complaint.

Judge Nelson overruled this objection as moot. Because the state court had issued its ruling and the defendants had already responded, the concern about open-ended delay was no longer a live issue. The court cited Haden v. Pelofsky, 212 F.3d 466, 469 (8th Cir. 2000), for the principle that changed circumstances can render issues moot.

Objection 2: Simultaneous Access to Sealed State Court Records

Magistrate Judge Brisbois had denied Edner's request for a court order requiring state officials to produce sealed records from his criminal case simultaneously to both parties in this federal action. The magistrate judge noted that Edner provided no legal authority for such an order and that Edner had declined to participate in the state court's established process for requesting access to sealed records.

In his objections, Edner again cited no authority showing the magistrate judge clearly erred or acted contrary to law. Instead, Edner proposed a "modification" that would require the defendants to produce any sealed materials they received from the state court within seven days. Judge Nelson noted this modification was not raised before the magistrate judge and thus could not serve as a proper basis for an objection at the district court level.

Additionally, the defendants represented that they had already provided Edner with the state court records they received on January 30, 2026, in the same form and on the same day they received them. Defendants also agreed to produce any records received from third-party executive branch agencies upon receipt, in the format received. The court noted the parties had not yet resolved logistics for County and City records that required counsel review before production, but suggested the parties would likely resolve this without court involvement.

Judge Nelson overruled Edner's objection on this issue.

Objection 3: Factual Recitations in the Order

Edner asked the court to modify three factual statements in the magistrate judge's order: (1) that he missed the December 18, 2025 hearing because of blizzard conditions (and had filed an emergency motion for a continuance); and (2) that his refusal to sign the defendants' proposed stipulation on records access was not opposition to access itself, but a request for what he called "parity safeguards."

Judge Nelson overruled this objection as well. The court held that these are not proper objections under Federal Rule of Civil Procedure 72(a) or Local Rule 72.2 because those rules only permit objections on grounds that a ruling is clearly erroneous or contrary to law. The court also noted the factual recitations Edner sought to modify were not determinative of any of the issues the magistrate judge decided.

Disposition

Judge Nelson overruled all of Edner's objections and affirmed Magistrate Judge Brisbois' January 20, 2026 Order in its entirety. The case continues, with defendants having filed a motion to dismiss the complaint.