Quinlan v. FD Software Enterprises

Background

Carsten Quinlan alleged that he was wrongfully charged with serious criminal offenses based on fabricated allegations during a custody and divorce dispute. He alleged that the accusations damaged his reputation and employment prospects, although he was acquitted in April 2024.

FD Software Enterprises, LLC extended Quinlan an offer for a software-engineer position. The offer stated that employment was at will and conditioned on passing a drug test and background check. After a background check disclosed pending Minnesota criminal charges, FD Software rescinded the offer.

Quinlan later worked for SaVia Health, Inc., which he alleged became aware of the pending charges. SaVia Health terminated him on or around August 15, 2023, citing performance-related issues. In 2025, Schneider National, Inc. extended Quinlan a conditional offer for a truck-driving position. After a recruiter asked about the prior criminal case and Quinlan explained that he had been acquitted, the recruiter told him Schneider National would not proceed with the employment.

Quinlan filed the action without a lawyer and later amended his complaint. He asserted claims for negligent infliction of emotional distress, promissory estoppel or detrimental reliance, wrongful discriminatory employment practices in violation of public policy, and declaratory relief based on constitutional principles of fairness and due process. Each defendant moved to dismiss the amended complaint under Rule 12(b)(6), which tests whether a complaint states a legally sufficient claim.

Court’s Analysis

Negligent Infliction of Emotional Distress

Under Minnesota law, a negligent-infliction-of-emotional-distress claim requires the elements of negligence—duty, breach, injury, and causation—plus proof that the plaintiff was in a zone of danger, reasonably feared for his own safety, and suffered severe emotional distress with related physical manifestations.

The court held that Quinlan did not allege facts showing that any defendant owed him the required duty of care. It relied on the at-will nature of his employment and the conditional nature of the FD Software and Schneider National offers. The court also concluded that Quinlan did not allege negligence by FD Software or SaVia Health because those defendants made their employment decisions before his acquittal and could not have known that he would not be convicted. Finally, the employment decisions did not place Quinlan in a physical zone of danger. The negligent-infliction-of-emotional-distress claims therefore failed.

Promissory Estoppel

Promissory estoppel requires a clear and definite promise, intended reliance that occurred, and enforcement necessary to prevent injustice. In the employment context, the court explained that the promise must be one of long-term employment terminable only for cause.

The court held that Quinlan did not allege such a promise. FD Software described the employment as at will and conditioned its offer on a background check. Schneider National’s offer was conditional, and Quinlan alleged no facts showing that the position would be long term or terminable only for cause. His allegations about working for SaVia Health for approximately three months and relying on continued job stability likewise did not establish a promise of long-term employment. The court dismissed the promissory-estoppel claim against all defendants.

Wrongful Employment Practices in Violation of Public Policy

The court held that Quinlan did not identify a statute, law, regulation, or specific public policy supporting this claim. It also found that his allegations were insufficient to state a claim against any defendant.

To the extent Quinlan asserted wrongful discharge against SaVia Health, the court explained that Minnesota recognizes a narrow exception to at-will employment when an employee is terminated for refusing to commit an act the employee reasonably and in good faith believed was illegal. Quinlan did not allege facts supporting that exception. The court dismissed this claim as asserted against each defendant.

Declaratory Relief

Quinlan sought a declaration under the federal Declaratory Judgment Act concerning his rights under the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The court explained that the Act creates a procedure for deciding existing rights but does not create a separate underlying claim.

The court noted that Quinlan alleged that current laws did not expressly prohibit discrimination based on past criminal accusations, and therefore concluded that he had not identified an underlying substantive right for the requested declaration. The court also held that the Fourteenth Amendment generally limits state action, while all three defendants were private employers. Quinlan alleged no facts that could make them state actors. The declaratory-relief claim therefore failed to state a claim.

Disposition

The court granted SaVia Health’s motion to dismiss, granted FD Software’s motion to dismiss, and granted Schneider National’s motion to dismiss. It denied as moot the defendants’ earlier motions directed at the original complaint because Quinlan had filed an amended complaint. The court dismissed the amended complaint with prejudice, stating that Quinlan had already amended once and could not state a viable claim under the facts alleged. The court ordered judgment to be entered.