Day v. State of Minnesota

Background

Roy A. Day filed an amended complaint against the State of Minnesota, the Minnesota Supreme Court, the Chief Justice of the Minnesota Supreme Court, Target Corporation, Starbucks Corporation, and the attorney and law firm that represented Target in Day’s state-court lawsuit. Day alleged that the defendants conspired to deprive him of due-process and equal-protection rights under the Fourteenth Amendment. He asserted claims under 42 U.S.C. § 1983 and 42 U.S.C. § 1985(3), along with state-law claims for infliction of emotional distress and fraud. He sought injunctive and declaratory relief, damages, costs, and attorneys’ fees exceeding $1 million.

The federal lawsuit followed a Minnesota state-court case in which Day alleged that Target and Starbucks fraudulently deprived him of four dollars. The state court denied his application to proceed without paying the filing fee because it found the lawsuit frivolous and closed the case for failure to pay the fee. The Minnesota Court of Appeals affirmed, and the Minnesota Supreme Court denied further review.

A magistrate judge recommended dismissing the federal claims as frivolous and the state claims for lack of subject-matter jurisdiction. The recommendation also advised denying Day’s pending application to proceed without paying filing fees as moot. Day objected.

Federal claims

The district court overruled Day’s objections and adopted the recommendation as to the federal claims. It held that a frivolous lawsuit lacks an arguable basis in law or fact, including when its allegations are fanciful, irrational, or wholly incredible.

For the § 1983 claims, the court explained that only state actors generally may be sued under that statute. A private party may qualify as a state actor if it willfully participates in joint activity with the state. The court concluded that Day’s allegations that Target, Starbucks, and Target’s attorneys acted jointly with the state defendants were fanciful and lacked an arguable basis in law and fact.

The court also concluded that the state defendants could not be sued under § 1983 on the allegations presented. It rejected Day’s reliance on Monell, explaining that Monell applies to local government units and does not permit suits against a state, state courts, or state court judges. The court further held that Day’s allegations supporting prospective equitable relief against the Chief Justice were clearly baseless because the only concrete fact alleged was her involvement in denying further review of Day’s state-court case.

The court separately considered the § 1985(3) conspiracy claims. It explained that such a claim requires allegations that the plaintiff belongs to a group subjected to invidious discrimination and that the defendants acted because of racial or class-based discriminatory animus. The court held that the Eleventh Amendment barred the claims against the state defendants and that Day’s allegations against the private defendants did not reasonably suggest membership in a protected class or the required discriminatory motive. The court characterized the alleged elaborate scheme to deprive Day of access to the courts and recover four dollars as irrational and wholly incredible.

The court therefore dismissed Counts One and Two—the federal claims—with prejudice.

State-law claims and final order

Day’s remaining claims alleged infliction of emotional distress and fraud under state law. The court concluded that the record did not establish original federal jurisdiction over those claims. It explained that Day did not invoke diversity jurisdiction in his amended complaint, and although his civil cover sheet indicated an intent to do so, the allegations did not plausibly support a recovery exceeding $75,000. The court therefore had jurisdiction over the state claims only through supplemental jurisdiction, which permits a federal court to hear related state claims. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction and dismissed the state claims without prejudice.

Judge Wilhelmina M. Wright ordered that Day’s objections be overruled, the magistrate judge’s March 22, 2019 report and recommendation be adopted, and the amended complaint be dismissed as follows: federal Counts One and Two were dismissed with prejudice; state Counts Three and Four were dismissed without prejudice; and Day’s application to proceed without paying filing fees was denied as moot.