Kasso v. City of Minneapolis and City of Minneapolis Police Department

Background

Leila Kasso sued the City of Minneapolis and the City of Minneapolis Police Department, alleging numerous incidents of race, gender, disability, and age discrimination during her time as a Minneapolis Police officer. The City served interrogatories and document requests during discovery.

After discovery reopened, the City asked the magistrate judge to compel fuller responses. At a November 4, 2025 hearing, U.S. Magistrate Judge Douglas L. Micko granted that request in part and set November 26, 2025, as the deadline for Kasso to substantially provide the requested information. A written minute entry also identified the discovery requests requiring fuller responses.

Kasso provided information that the City viewed as incomplete and repeated objections that Judge Micko had rejected. She also did not appear for a deposition scheduled for January 7, 2026. The City then moved for sanctions, seeking dismissal of Kasso’s claims and payment of its expenses.

On February 19, 2026, Judge Micko granted in part and denied in part the sanctions motion. He denied dismissal of Kasso’s claims but ordered her to pay the City $4,596.21 in attorney and paralegal fees and $348.00 in deposition costs. Kasso, who was representing herself, objected to that order.

Review standard and issues

The district court reviewed the objections under Federal Rule of Civil Procedure 72(a). Under that rule, the court could set aside the magistrate judge’s order only if it was clearly erroneous or contrary to law. The court described this as a highly deferential standard.

Kasso argued that she lacked adequate notice of the discovery deadline and requirements, that Judge Micko misapplied the discovery-sanctions rules, and that the underlying discovery order was improper. The district court considered only whether the sanctions order was proper. It ruled that Kasso’s later, separate objections were untimely and were not properly before the court.

Court’s analysis

The court held that an oral order can support discovery sanctions when it clearly informs a party what must be done. It found that Kasso was present when Judge Micko announced the November 26 deadline, that he explained what he expected, and that the written minute entry repeated the deadline and identified the discovery requests. The court therefore rejected Kasso’s lack-of-notice argument.

The court also rejected Kasso’s argument that the City could not recover expenses related to seeking dismissal because dismissal was not granted. It concluded that the expenses of bringing the sanctions motion were caused by Kasso’s discovery violations and that the governing rules allow recovery of reasonable expenses caused by failing to obey a discovery order or attend a deposition.

The court agreed with Judge Micko that Kasso’s failure to attend the deposition was not substantially justified. The City had sent the deposition notice by email and U.S. mail, and Kasso had replied to an email thread repeating the deposition date. The court also found no legal error in the amount of the award, noting that Judge Micko had reduced the requested attorney’s fees and excluded certain other requested expenses.

Finally, the court did not consider Kasso’s challenges to the underlying discovery order because the deadline for objecting to that order had passed. It stated that those issues were not properly before the court in the review of the sanctions order.

Disposition

The court overruled Kasso’s objections and affirmed Judge Micko’s order granting in part and denying in part the City’s motion for sanctions. It ordered Kasso to pay the City $4,596.21 in attorney and paralegal fees and $348.00 in deposition costs. The court modified the payment deadline, requiring payment by June 1, 2026, rather than May 1, 2026.