Larson v. Taubell Corporation

Background

Richard A. Larson, Jr. brought claims under the Americans with Disabilities Act (ADA) and Minnesota state law. He did not pay the filing fee and instead applied to proceed without paying it, which led to pre-service screening under 28 U.S.C. § 1915(e)(2). In that earlier screening, the court determined that the complaint did not plausibly state a federal claim. The court found that Larson had not clearly alleged that he had a disability, and that his retaliation claim did not identify whether it arose under state or federal law or allege protected activity under the ADA or another federal statute.

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over the remaining state-law claims and dismissed them so they could be considered, if at all, by Minnesota courts. The court entered judgment dismissing the complaint without prejudice on February 18, 2026.

Motion to Alter or Amend

On March 18, 2026, Larson moved under Rule 59(e) of the Federal Rules of Civil Procedure to alter or amend the judgment, vacate it, reopen the case, and allow him to amend his complaint. He argued that the deficiencies identified by the court could be cured through amendment. He submitted a proposed amended complaint and an Equal Employment Opportunity Commission right-to-sue letter dated September 8, 2025.

Rule 59(e) provides a limited mechanism for correcting a manifest error of law or fact or considering newly discovered evidence. The court explained that the rule is not a vehicle for presenting evidence that could have been submitted earlier or for raising new legal theories or arguments that could have been made before judgment. Although courts may consider the ordinary rules governing amendment of pleadings, post-judgment amendment must also satisfy Rule 59(e)’s stricter requirements.

Court’s Analysis

The court found that Larson did not identify an error of law or fact in the earlier dismissal. The right-to-sue letter was issued months before Larson filed his complaint, so it was not newly discovered evidence supporting Rule 59(e) relief.

The court also examined the proposed amended complaint and concluded that it would not cure the prior deficiencies. Larson still did not identify the federal statute supporting his retaliation claim or specify protected activity. For his ADA claim, he alleged that he was regarded as disabled and was terminated because defendants perceived him as having a mental impairment. The court found those allegations conclusory and insufficient to state a plausible claim, including because they did not suggest that his employer regarded him as unable to work in a broad class of jobs.

Because the proposed amendment still did not state a plausible federal claim, the court concluded that the amended complaint would leave only state-law claims. The court stated that it would again decline supplemental jurisdiction over those claims and dismiss them for the same reason as before.

Disposition

Judge Laura M. Provinzino denied Larson’s Motion to Alter or Amend Judgment and To Reopen Case with Leave To File Amended Complaint. The court stated that the matter was closed. It also noted that the original complaint had been dismissed without prejudice, meaning Larson may attempt to correct the pleading deficiencies and open a new matter.