Bowens v. City of Minneapolis
Shomari Bowens v. City of Minneapolis; Hennepin County; Rashida Bowens, individually and in her official capacity; Michael Wolf, individually and in his official capacity
- Jeffrey Bryan
- 0:26-cv-00268
- U.S. District Court · District of Minnesota
- 12
In Bowens v. City of Minneapolis, Judge Bryan dismissed pro se plaintiff Shomari Bowens's civil-rights lawsuit without prejudice, finding the federal court lacked jurisdiction under the Rooker-Feldman doctrine because the claims were tied to a prior state court property ruling.
Pro se litigants who have lost property-related disputes in state court and then seek to re-litigate those disputes in federal court as constitutional claims; individuals facing municipal property forfeiture or tax proceedings who may be subject to the Rooker-Feldman doctrine barring federal court review of state court judgments.
What happened
In Bowens v. City of Minneapolis (No. 26-CV-00268), Shomari Bowens, representing himself, sued the City of Minneapolis, Hennepin County, Rashida Bowens, and Michael Wolf, alleging that defendants violated his constitutional rights by attempting to dispossess him of property at 2424 Aldrich Ave. N. He brought claims under the Fourth, Fifth, Eighth, and Fourteenth Amendments through the federal civil-rights statute, 42 U.S.C. § 1983, seeking declaratory relief, an injunction to stop the dispossession, and money damages.
The defendants moved to dismiss Bowens's First Amended Complaint on several grounds, including that the federal court lacked the power to hear the case. They argued, among other things, that Bowens was essentially asking the federal court to overturn or ignore a December 22, 2025 Minnesota state court judgment that had already resolved a property and tax dispute involving the same property. Bowens also sought to file a greatly expanded Second Amended Complaint and requested a temporary restraining order to halt the threatened eviction, but he did not file a response to the defendants' motions to dismiss by the court's deadline and later sought an extension of time.
Judge Jeffrey M. Bryan denied all of Bowens's motions and granted the defendants' motions to dismiss. The court found it lacked jurisdiction under the Rooker-Feldman doctrine, which bars federal district courts from reviewing or undercutting state court judgments — a power reserved for the U.S. Supreme Court. Because Bowens's federal claims could only succeed if the state court had wrongly decided the property dispute, the federal court could not hear them. The case was dismissed without prejudice, meaning Bowens is not barred by this order alone from seeking other available relief. The motion to add a Second Amended Complaint was denied as futile because the proposed filing was 52 pages and 318 paragraphs long, was confusing and repetitive, and failed to meet basic pleading rules. The request for an extension of time was denied because Bowens did not show an excusable reason for missing the deadline, and the request for a temporary restraining order was denied as moot.
The detailed version
- Bowens v. City of Minneapolis · No. 0:26-cv-00268
- Jeffrey M. Bryan
- Aug. 17, 2026
Background
Shomari Bowens, representing himself, filed this lawsuit on January 13, 2026, followed by a First Amended Complaint (FAC) on February 3, 2026. Bowens alleged that the City of Minneapolis, Hennepin County, Rashida Bowens (sued individually and in her official capacity), and Michael Wolf (sued individually and in his official capacity) violated his constitutional rights in connection with efforts to dispossess him of property located at 2424 Aldrich Ave. N. (the Property).
Bowens's FAC asserted claims under the Fourth, Fifth, Eighth, and Fourteenth Amendments to the U.S. Constitution, brought through 42 U.S.C. § 1983 (the primary federal statute allowing individuals to sue state and local government officials for constitutional violations). He alleged that defendants issued notices and demands asserting authority to dispossess him of the Property without judicial authorization and without giving him a judicial process to challenge that authority. He sought declaratory relief, injunctive relief, and money damages.
A prior Minnesota state court decision dated December 22, 2025 — which Bowens himself referenced in the FAC — had addressed a property and tax dispute involving the same property. The state court found that Bowens had already "expressly waived his claims" regarding the tax proceedings and denied his motions to stay or bar foreclosure proceedings.
Procedural History
In lieu of answering the FAC, defendants filed motions to dismiss on May 20, 2026, raising arguments including lack of standing, various grounds for lack of subject matter jurisdiction (including the Rooker-Feldman doctrine), and failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Bowens's deadline to respond to those motions was June 11, 2026. He did not respond by that date and did not seek an extension before the deadline passed.
On June 8, 2026, Bowens filed a Motion for Leave to File a Second Amended Complaint (SAC). The proposed SAC was 52 pages long and contained 318 paragraphs — roughly 47 pages more than the FAC. On June 9, 2026, he filed a second Motion for Preliminary Injunction and Temporary Restraining Order. On June 26, 2026, he filed a motion for extension of time to submit additional exhibits and a reply brief on the motion to amend; the court denied that request. On July 22, 2026, defendants filed a letter noting Bowens had not responded to their motions to dismiss. Bowens then filed a late Motion for Extension of Time to respond to the motions to dismiss, and subsequently filed numerous additional documents without seeking leave.
Rulings
Motion to Amend (Denied)
The court first addressed whether Bowens could amend his pleadings before ruling on the motions to dismiss. Under Federal Rule of Civil Procedure 15(a)(2), courts should freely grant leave to amend when justice requires, but may deny leave where amendment would be "futile" — meaning the amended complaint could not survive a motion to dismiss.
The court found the proposed SAC would be futile because it failed to comply with Federal Rule of Civil Procedure 8(a)(2), which requires a "short and plain statement of the claim showing that the pleader is entitled to relief." The court described the SAC as a "shotgun" or "kitchen-sink"-style pleading: at 52 pages and 318 paragraphs, it was unreasonably lengthy, repetitious, and confusing; it lumped defendants together without specifying which defendant did what; it cited almost no legal authority; and it referenced documents without exhibit citations, making it impossible for the court to identify what was in the factual record. The court noted that Bowens also failed to comply with local rules requiring a redlined comparison of the proposed amendment to the existing pleading, and failed to meet and confer with defendant City of Minneapolis before filing — failures that independently justified denial.
Motion for Extension of Time (Denied)
Bowens sought permission to file a late response to the motions to dismiss under Federal Rule of Civil Procedure 6(b), which allows extensions after a deadline has passed only upon a showing of "excusable neglect." The court found Bowens did not establish excusable neglect. Bowens offered only the conclusory assertion that he needed more time to prepare a meaningful response, but did not explain why he failed to seek an extension before the deadline. The court noted that Bowens had already demonstrated familiarity with seeking extensions in this case before the deadline passed. A nearly six-week delay with no substantive reason did not qualify as excusable neglect.
Motions to Dismiss the FAC (Granted; Case Dismissed Without Prejudice)
The court granted defendants' motions to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), applying the Rooker-Feldman doctrine.
The Rooker-Feldman doctrine (derived from D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983)) provides that federal district courts lack jurisdiction to review or grant relief from state court judgments; that power belongs exclusively to the U.S. Supreme Court. The doctrine also applies to federal claims that are "inextricably intertwined" with a state court judgment — meaning claims that can succeed only if the state court wrongly decided the issues before it.
The court found Bowens's claims inextricably intertwined with the December 22, 2025, Minnesota state court judgment. The FAC itself acknowledged that prior judgment, and Bowens's constitutional claims about dispossession of the Property could succeed only if the federal court set aside or overrode what the state court had already decided. The court further noted that dressing up state law property challenges as § 1983 constitutional claims does not allow a litigant to avoid the Rooker-Feldman bar. Because the court lacked jurisdiction, it did not reach defendants' alternative arguments regarding standing, other jurisdictional grounds, or failure to state a claim on the merits.
The action was dismissed without prejudice.
Motion for Preliminary Injunction and Temporary Restraining Order (Denied as Moot)
Because the case was dismissed for lack of jurisdiction, Bowens's second Motion for Preliminary Injunction and Temporary Restraining Order was denied as moot.
Motion for Leave to File a Reply (Denied)
Bowens's additional Motion for Leave to File a Reply (Doc. No. 91) was denied as duplicative and procedurally improper.
Summary of Dispositions
- Motion for Leave to File Second Amended Complaint: Denied - Motion for Extension of Time: Denied - Motion for Leave to File a Reply: Denied - Defendants' Motions to Dismiss: Granted - Case: Dismissed without prejudice - Motion for Preliminary Injunction and Temporary Restraining Order: Denied as moot
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.