Harris v. St. Peter Investors

Background

William Malik Harris brought the case on May 27, 2025, asserting federal and state claims against St. Peter Investors, LLC; Avidity Real Estate Services, LLC; and Gregg Stellick. The opinion states that Harris was representing himself. Avidity and Stellick were served but did not answer. The Clerk therefore entered default against them under Federal Rule of Civil Procedure 55(a). Harris then moved under Rule 55(b) for default judgment against Avidity and Stellick.

Harris alleges that he signed a residential lease with Avidity on January 26, 2024, and was allowed to keep a service dog in his apartment. He alleges that St. Peter functioned as the de facto owner and landlord, and that Stellick was the managing principal of both corporate defendants. Harris further alleges that St. Peter began eviction proceedings, that he was locked out of his apartment on March 27, 2025, and that his service dog remained inside for 10 hours without food or water. He asserts claims under the Fair Housing Act, 42 U.S.C. § 1981, the Fourth Amendment, similar Minnesota constitutional protections, and the Minnesota Human Rights Act. He seeks $50 million in damages.

Default-Judgment Analysis

The court explained that default judgment involves two steps: entry of default by the Clerk, followed by a possible judgment from the court. Although the Clerk had entered default, default judgment remained discretionary. Courts generally avoid default judgments when a defendant who has appeared and a defaulting defendant are similarly situated or have closely related defenses, because a judgment for the answering defendant could conflict with a judgment against the defaulting defendant.

The court found that concern present here. Harris’s complaint alleges that St. Peter acted as his landlord and directed Avidity’s actions. It also alleges that Stellick managed both corporate defendants and that Avidity and St. Peter operated as a single enterprise. Harris’s motion argued that the defendants’ conduct was factually and legally distinct and that no joint liability existed, but the court concluded that those arguments conflicted with allegations in his complaint. The court therefore held that the better approach was to defer judgment against Avidity and Stellick until the merits of the case had been resolved.

Citations and Possible Sanctions

The court also stated that Harris repeatedly misquoted cases and supplied citations to authorities that did not appear to exist. The court questioned whether artificial-intelligence tools had been used, but it did not determine that they had been. It emphasized that all litigants must verify the accuracy of filings and legal authorities. The court said Harris had likely violated Federal Rule of Civil Procedure 11, which requires an unrepresented party to ensure that legal arguments in a filed motion are supported by existing law.

Because the court had not previously warned Harris that false authority could lead to sanctions, it declined to strike the motion. It warned, however, that continued inaccurate filings could result in sanctions.

Disposition

Judge Laura M. Provinzino ordered that Harris’s motion for default judgment, ECF No. 55, was denied without prejudice. The opinion did not decide the underlying claims or enter judgment for any party.