Jensen v. Minnesota Department of Human Services

Background

The court had approved the parties’ stipulated class-action settlement agreement on December 5, 2011, and retained jurisdiction to supervise compliance. It later adopted a Comprehensive Plan of Action containing evaluation criteria and related actions. The court extended its jurisdiction several times because of continuing concerns about defendants’ compliance. The Eighth Circuit affirmed the court’s authority to extend its jurisdiction as it deemed “just and equitable.”

In January 2019, the court required defendants to submit a comprehensive summary report about compliance. At an April 16, 2019 status conference, the parties disagreed about whether defendants had fully complied. In its June 17, 2019 order, the court extended jurisdiction to September 15, 2020, pending additional information, including external verification of compliance and information about several identified areas of concern.

The motion

Defendants moved under Rule 59(e) of the Federal Rules of Civil Procedure. That rule permits a court to change an order in limited circumstances, including a manifest error of law or fact or newly discovered evidence. Defendants argued that the court had not given them adequate prior notice that it might extend jurisdiction or a sufficient opportunity to address the concerns underlying the extension. They asked the court to vacate the June 2019 order and terminate its jurisdiction.

Plaintiffs argued that defendants were improperly trying to reargue issues the court had already decided. Plaintiffs also maintained that defendants had received ample notice and opportunities to be heard.

Court’s analysis

The court found that defendants had adequate notice that it was considering whether to continue its jurisdiction. Earlier orders had stated that the court reserved authority to extend jurisdiction, and the January 2019 order explained that the summary report and status conference would help determine whether jurisdiction could end. The court also found that defendants had a sufficient opportunity to be heard, including during the status conference, where they argued that the court had enough information to find full compliance.

The court determined that defendants’ motion largely repeated their position that they were fully compliant and that additional requirements exceeded the settlement agreement’s scope. The court had already considered and rejected those arguments. It also found that information defendants submitted with the motion did not resolve the court’s concerns because it lacked the external verification the court had required.

Disposition

The court concluded that defendants had identified no manifest error of law or fact, newly discovered evidence or law, or other extraordinary circumstance warranting relief. It therefore denied defendants’ Motion to Alter or Amend the June 17, 2019 Order. The court stated that it would end its jurisdiction when it received sufficient evidence that defendants were complying with the agreement and that ending jurisdiction would be just and equitable.