Williams v. Satriano
DeLaQuay Williams v. Christine Satriano, in her individual and official capacity, et al.
- Katherine Menendez
- 0:24-cv-02618
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Williams v. Satriano, Judge Menendez adopted a magistrate's recommendation, granting in part and denying in part a motion to dismiss and dismissing only the emotional-distress claim.
Plaintiffs who bring claims against government officials in their individual and official capacities, particularly those asserting emotional distress claims alongside other causes of action; parties who fail to object to a magistrate judge's recommendation, which limits the district court's review to clear error only.
What happened
In DeLaQuay Williams v. Christine Satriano, plaintiff DeLaQuay Williams filed an amended complaint against defendant Christine Satriano, among others. Satriano moved to dismiss the amended complaint, and United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation on February 23, 2026, concluding that the motion should be granted as to Williams's claim for negligent infliction of emotional distress against Satriano, but denied as to all other claims.
Neither party objected to the magistrate judge's recommendation within the 14-day objection period, nor in the roughly three additional weeks that followed. Because no objections were filed, the district court reviewed the recommendation only for clear error — a more limited review than if objections had been raised.
Judge Katherine M. Menendez found no clear error and adopted the Report and Recommendation. As a result, Satriano's motion to dismiss was granted in part and denied in part: the negligent infliction of emotional distress claim against Satriano was dismissed, while the remaining claims in the amended complaint were allowed to proceed.
The detailed version
- Williams v. Satriano · No. 0:24-cv-02618
- Katherine Menendez
- Mar. 31, 2026
Background
Plaintiff DeLaQuay Williams filed an amended complaint (Dkt. 56) against defendant Christine Satriano and others. The amended complaint includes multiple claims, one of which is negligent infliction of emotional distress against Satriano.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R&R) on February 23, 2026 (Dkt. 82), recommending that Satriano's Motion to Dismiss (Dkt. 66) be granted in part and denied in part. Specifically, Judge Elkins recommended: - Grant the motion as to Williams's claim for negligent infliction of emotional distress against Satriano. - Deny the motion in all other respects.
Standard of Review
Under District of Minnesota Local Rule 72.2(b)(1) and Federal Rule of Civil Procedure 72(b), parties have 14 days to object to a magistrate judge's R&R. When no objections are filed, the district court reviews the R&R for clear error only — a deferential standard under which the court will adopt the recommendation unless there is a plain mistake. Neither party filed objections within the 14-day period or in the approximately three additional weeks before the district court's order.
Ruling
Judge Menendez found no clear error in the R&R and adopted it in full. The court ordered:
- The R&R (Dkt. 82) is accepted.
- Satriano's Motion to Dismiss (Dkt. 66) is granted in part and denied in part.
- The amended complaint's claim for negligent infliction of emotional distress against Satriano is dismissed.
The opinion does not specify whether the dismissal is with or without prejudice, and it does not address the nature of the remaining surviving claims in detail beyond noting that the motion was otherwise denied.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.