Hazley v. State of MN
- Eric Tostrud
- 0:16-cv-03935
- U.S. District Court · District of Minnesota
- 4
In Hazley v. Dooley, Judge Tostrud denied Hazley’s summary-judgment motion without prejudice, denied defendants’ extension request as moot, and postponed new motions until settlement.
Glenn Kevin Hazley, Becky Dooley, and Kristi Cisar were affected by the rulings. The order also imposed a case-wide restriction preventing either party from filing for summary judgment until after a good-faith settlement conference.
What happened
In Hazley v. Dooley and Cisar, Glenn Kevin Hazley, who was representing himself, claimed that two correctional-facility officials prevented him from accessing money needed to post bail and be released. He brought federal civil-rights and state false-imprisonment claims.
Hazley asked for judgment in his favor, but his motion and supporting memorandum did not identify facts or record evidence showing that no important factual dispute existed. Discovery was still underway, and the defendants had asked for more time to respond while indicating they might later seek summary judgment.
Judge Eric C. Tostrud denied Hazley’s motion without prejudice, meaning he could file another summary-judgment motion later. The judge denied the defendants’ extension request as moot and ordered that neither side file for summary judgment until after participating in good faith in a settlement conference.
The detailed version
- Hazley v. State of MN · No. 0:16-cv-03935
- Eric Tostrud
- Apr. 23, 2019
Background
Glenn Kevin Hazley was incarcerated at the Minnesota Correctional Facility in Moose Lake when the Minnesota Court of Appeals determined that his sentence was unauthorized and sent his criminal case back to the district court for further proceedings. After the remand, the district court set bail. Hazley attempted to use funds in his inmate account to post bail and obtain release while those proceedings continued.
Hazley filed this civil case without a lawyer. He alleged that three facility officials violated 42 U.S.C. § 1983, a federal civil-rights statute, and committed the state-law tort of false imprisonment by preventing him from accessing his inmate account. His claims against Becky Dooley and Kristi Cisar had survived two earlier motions to dismiss.
Hazley’s Motion
Hazley filed a document titled “Motion for Judgment.” The court interpreted it as a motion for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is a decision without a trial when the moving party shows that no genuine dispute exists about any material fact and that the party is entitled to judgment as a matter of law.
The court found that Hazley’s motion and two-paragraph legal memorandum did not make that showing. The memorandum largely repeated the text of Section 1983 and described the damages Hazley sought, but it did not provide facts or citations to evidence in the record supporting liability by Dooley and Cisar. The court noted that much discovery had not yet occurred.
Other Motion and Case Schedule
The defendants sought an unspecified extension of time to respond to Hazley’s motion. They also indicated that they anticipated filing their own summary-judgment motion later. A scheduling order set October 17, 2019, as the discovery deadline and December 16, 2019, as the deadline for dispositive motions. The case had also been assigned to the Early Settlement Conference Project, with a planned effort to locate a lawyer to assist Hazley at the settlement conference.
Ruling
Judge Eric C. Tostrud ordered that:
- Hazley’s motion for judgment was denied without prejudice to his right to re-file for summary judgment later.
- The defendants’ motion for an extension of time was denied as moot because Hazley’s motion was denied.
- Neither party could file a summary-judgment motion until after the parties participated in good faith in a settlement conference through the Early Settlement Conference Project.
The order did not decide whether Hazley ultimately would prevail on his civil-rights or false-imprisonment claims. It explained that filing a summary-judgment motion before discovery ends carries the risk that the opposing party may need additional discovery to respond.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.