Murphy v. Minnesota Department of Human Services
- Donovan Frank
- 0:16-cv-02623
- U.S. District Court · District of Minnesota
- 3
In Murphy v. Wheelock, Judge Frank denied the defendant’s request to seek reconsideration of the order refusing to decertify the class.
The ruling directly affected Pam Wheelock’s request for permission to seek reconsideration and left in place the earlier order denying decertification of the class represented by Tenner Murphy, Marrie Bottelson, and Dionne Swanson.
What happened
Murphy v. Minnesota Department of Human Services concerns the defendant’s request for permission to ask the court to reconsider its earlier refusal to decertify the class. The defendant argued that the court had overlooked her position about later legal authority and the evidence developed during the case.
The court rejected those arguments. It said it already knew about the relevant authority, had considered the record, and had addressed the defendant’s arguments about the class representatives and a particular interrogatory. The court also said reconsideration is reserved for extraordinary circumstances, not for repeating arguments that were already rejected.
The court concluded that the defendant had not shown the required compelling circumstances and denied her request for permission to file a reconsideration motion. Judge Donovan W. Frank signed the order.
The detailed version
- Murphy v. Minnesota Department of Human Services · No. 0:16-cv-02623
- Donovan Frank
- Aug. 14, 2019
Background
The defendant, Pam Wheelock, sought permission under the District of Minnesota’s local rules to file a motion asking the court to reconsider its July 26, 2019 order. That earlier order had denied the defendant’s motion to decertify the class, meaning to remove the case’s class-action status. The plaintiffs opposed the request.
Arguments
The defendant argued that the court had erred by ruling without hearing from her about additional legal authority, relying on allegations in the amended complaint instead of facts discovered during the litigation, and relying on the entire record rather than the plaintiffs’ answer to one interrogatory.
Court’s analysis
The court explained that permission to seek reconsideration requires “compelling circumstances.” It said reconsideration should not be used to relitigate issues that have already been decided, but instead is available in extraordinary circumstances.
The court found that it was already familiar with the relevant issues and authorities when it issued the earlier order. It also stated that it knew about the reversal of a decision the defendant had cited and had already considered that development in its analysis. The court said that neither the plaintiffs’ supplemental letter nor the defendant’s response changed its independent analysis.
The court rejected the argument that it improperly relied on an earlier order describing the facts. It said that the earlier order supplemented the relevant facts as needed. The court also continued to find unpersuasive the defendant’s argument that Ms. Swanson was not an adequate class representative, noting that only one adequate representative was needed and that two other adequate representatives remained even without her.
Finally, the court characterized the defendant’s argument about the single interrogatory as an unsupported attempt to relitigate an issue it had already considered and rejected.
Disposition
The court concluded that the defendant had not shown the compelling circumstances required to justify reconsideration. It therefore DENIED the defendant’s request for leave to file a motion for reconsideration. Judge Donovan W. Frank signed the order on August 14, 2019.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.