Randle v. Dakota County
Darien Tyrell Randle v. Dakota County; John and Jane Does, in their individual and official capacities; City of Hastings; and Dakota County Jail
- Laura Provinzino
- 0:26-cv-02844
- U.S. District Court · District of Minnesota
- 2
In Randle v. Dakota County, Judge Provinzino adopted a magistrate judge's recommendation dismissing most claims against all named defendants without prejudice, while allowing the plaintiff to file an amended complaint by October 30, 2026.
Darien Tyrell Randle, who brought this lawsuit, had most of his claims dismissed without prejudice but retains the ability to refile an amended complaint. People who have filed civil rights or other suits against municipalities or jails and are navigating court procedures regarding named versus unnamed defendants may find this order relevant.
What happened
In Randle v. Dakota County, No. 26-cv-2844, plaintiff Darien Tyrell Randle filed suit in the U.S. District Court for the District of Minnesota against Dakota County, the City of Hastings, the Dakota County Jail, and unnamed John and Jane Doe defendants in both their individual and official capacities. A magistrate judge issued a Report and Recommendation on August 3, 2026, recommending that most of the claims be dismissed.
Because no party objected to the magistrate judge's Report and Recommendation, the district court reviewed it only for clear error — a less intensive standard of review than if objections had been filed. Finding no clear error, the court adopted the Report and Recommendation in full.
Judge Laura M. Provinzino issued an order on September 3, 2026, dismissing without prejudice all claims against Dakota County, the City of Hastings, and the Dakota County Jail, and also dismissing without prejudice the official-capacity claims against the unnamed Doe defendants. The individual-capacity claims against the Doe defendants were not dismissed. Randle was reminded that he must file an amended complaint — naming at least one identified defendant and stating a viable legal claim — by October 30, 2026, or his entire complaint may be dismissed without prejudice under the federal rule governing timely service of process.
The detailed version
- Randle v. Dakota County · No. 0:26-cv-02844
- Laura M. Provinzino
- Sept. 3, 2026
Background
Plaintiff Darien Tyrell Randle filed a complaint in the U.S. District Court for the District of Minnesota against four defendants: Dakota County, the City of Hastings, the Dakota County Jail, and unnamed John and Jane Doe defendants sued in both their individual and official capacities. The opinion does not describe the underlying facts or specific legal claims in Randle's complaint beyond what is noted here.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on August 3, 2026, recommending partial dismissal of Randle's complaint. The R&R also set a deadline requiring Randle to file an amended complaint stating a viable claim for relief against at least one identified defendant by October 30, 2026, or face dismissal under Federal Rule of Civil Procedure 4(m) — the rule requiring that defendants be served within a set time after filing.
Standard of Review
Because no party objected to the R&R within the time permitted by Federal Rule of Civil Procedure 72(b)(2), Judge Provinzino reviewed it under the clear error standard — a deferential standard that requires adoption unless the reviewing court identifies an obvious mistake. The court found no clear error and adopted the R&R in full.
Rulings
The court entered the following specific dispositions:
- All claims against Dakota County, the City of Hastings, and the Dakota County Jail were dismissed without prejudice — meaning Randle is not barred from refiling those claims if the deficiencies can be corrected. - Official-capacity claims against the John and Jane Doe defendants were dismissed without prejudice. - Individual-capacity claims against the John and Jane Doe defendants were NOT dismissed; those claims survive at this stage.
What Happens Next
Randle must file an amended complaint by October 30, 2026, that states a viable claim for relief against at least one specifically identified defendant. If he fails to do so, the court indicated the complaint will be dismissed without prejudice under Federal Rule of Civil Procedure 4(m), which relates to timely service of process on defendants.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.