Kedrowski v. Madden

Background

David M. Kedrowski sued fourteen defendants, including Minnesota state officials connected to the Fourth Judicial District, Hennepin County and a county attorney, and several organizations and individuals involved in domestic-abuse advocacy or grant-related work. He alleged that the Fourth Judicial District became biased after accepting a grant from the Office on Violence Against Women. According to Kedrowski, the district adopted policies that favored alleged domestic-abuse victims and created obstacles for people accused of domestic abuse.

Kedrowski based his allegations on an order for protection proceeding and a divorce proceeding. In the order-for-protection case, a judge initially required him to leave his house and altered his custodial rights concerning his child. Three weeks later, another judge dismissed the order for protection, finding that the allegations did not meet the definition of domestic abuse. In the divorce proceeding, Kedrowski alleged that Referee Mary E. Madden was biased against him and required him to obtain permission before filing motions, including motions concerning child custody. He appealed the divorce proceeding to the Minnesota Court of Appeals.

Kedrowski asserted eight claims under a federal civil-rights law and one claim under a federal conspiracy law. The claims included alleged violations of the rights to an independent and impartial tribunal, equal rights, procedural due process, and substantive due process, as well as alleged failures to train and supervise.

Court’s Analysis

The magistrate judge recommended granting the defendants’ motions to dismiss and denying Kedrowski’s request for limited discovery and an evidentiary hearing. Kedrowski objected to the recommendation. Because he was representing himself, the district court read his objections liberally and independently reviewed the portions to which he objected.

The district court adopted the recommendation to dismiss under the Younger abstention doctrine. Abstention means that a federal court declines to exercise its authority in certain circumstances. The court explained that this doctrine applies when there is an ongoing state proceeding, the proceeding involves important state interests, and the state proceeding provides an adequate opportunity to raise the federal issues.

The court found all three conditions satisfied. When Kedrowski filed his federal complaint, his divorce proceeding was pending on appeal in the Minnesota Court of Appeals. The proceeding involved family and domestic-relations matters, which the court treated as an important state interest. The court also found that Kedrowski had an adequate opportunity to raise his federal claims in the state proceedings because his appeal raised the same issues, including alleged judicial bias.

The court rejected Kedrowski’s argument that his federal case would not interfere with the state proceeding. It reasoned that a ruling declaring aspects of the divorce proceeding unconstitutional would affect how state courts conduct divorce cases. The court also rejected his argument that extraordinary circumstances justified an exception. The fact that one judge had dismissed the order for protection undermined his claim that the entire Fourth Judicial District was biased, and he did not allege facts showing that Referee Madden had a financial or other vested interest in the outcome. The court concluded that his allegations did not establish systematic bias sufficient to overcome the presumption that the state tribunal was impartial.

Other Requests and Disposition

Because the court did not need to decide the personal-jurisdiction issue raised by the New York defendants, it denied Kedrowski’s request for discovery and an evidentiary hearing concerning that issue. The court expressly declined to adopt the recommendation’s other grounds for dismissal because addressing them would have been advisory.

The court adopted the April 9, 2019 Report and Recommendation in part. It granted the motions to dismiss filed by the Minnesota Coalition for Battered Women and Elizabeth Richards; Ivy S. Bernhardson, Robert A. Blaeser, Catherine S. Brey, Mary E. Madden, Christy Snow-Kaster, and Edward T. Wahl; Hennepin County and Lolita Ulloa; the Fund for the City of New York and Liberty Aldrich; and the Battered Women’s Justice Project. It dismissed Kedrowski’s amended complaint without prejudice and denied his motion for discovery and an evidentiary hearing.