Beaulieu v. Stockwell
- Donovan Frank
- 0:16-cv-03586
- U.S. District Court · District of Minnesota
- 14
In Beaulieu v. Stockwell, Judge Frank granted Sanvik summary judgment and dismissed Beaulieu’s claims with prejudice over allegedly missing photographs.
Allen Beaulieu’s claims against Charles Willard “Chuck” Sanvik were dismissed with prejudice. The ruling addressed Sanvik’s claims only and did not decide the separately noted summary-judgment motion by Clint Stockwell.
What happened
In Beaulieu v. Stockwell, Allen Beaulieu claimed that Charles Willard “Chuck” Sanvik possessed or helped others use Beaulieu’s photographs without permission. Beaulieu sued Sanvik for conversion, interference with a possible business opportunity, and injunctive relief.
Sanvik argued that he had not possessed Beaulieu’s physical photographs and had done nothing improper with them. The court found that Beaulieu’s evidence about missing photographs relied too heavily on memory and lacked reliable inventories showing what he had, provided, and recovered.
Judge Donovan W. Frank granted Sanvik’s motion for summary judgment. The court dismissed all claims against Sanvik with prejudice, including the interference claim, which had previously been dismissed without prejudice and was not amended.
The detailed version
- Beaulieu v. Stockwell · No. 0:16-cv-03586
- Donovan Frank
- Dec. 7, 2018
Background
Allen Beaulieu, individually and doing business as Allen Beaulieu Photography, photographed Prince for several years. Beaulieu alleged that he gave Clint Stockwell and Thomas Martin Crouse thousands of photographs to scan for a proposed book but that many were not returned. He also alleged that the photographs were used or circulated without his knowledge or consent.
Charles Willard “Chuck” Sanvik was added as a defendant after the case began. Beaulieu asserted three claims against Sanvik: conversion, tortious interference with prospective advantage, and injunctive relief. Sanvik moved for summary judgment, which asks whether the evidence shows a genuine factual dispute requiring a trial.
Court’s Analysis
The court concluded that Beaulieu had not provided enough evidence to support his allegation that Sanvik or the other defendants still possessed more than 5,000 photographs. Beaulieu’s estimates varied from about 3,000 to 6,000 photographs. His later inventories were based largely on his memory and did not identify the specific photographs he had possessed, given to Stockwell and Crouse, or recovered. There was also no inventory of the 35mm photographs.
The court held that this evidence was speculative and insufficient to create a genuine dispute of material fact. It also found no evidence that Sanvik possessed the physical photographs beyond receiving a slideshow email containing low-resolution copies. The court stated that Minnesota law does not recognize conversion of intellectual property and found no evidence that Sanvik conspired with the other defendants to use the photographs without permission.
Because Beaulieu’s underlying tort claims failed, the court also rejected his request for injunctive relief. The court noted that it had previously dismissed the tortious-interference claim without prejudice, but Beaulieu had not amended his complaint further.
Ruling
Judge Donovan W. Frank granted Sanvik’s motion for summary judgment. The order dismissed Beaulieu’s amended complaint as asserted against Sanvik with prejudice. The court separately dismissed the tortious-interference claim with prejudice because Beaulieu did not further amend it.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.