Brown v. Pfeiffer

Background

Shatara Brown, Nikoe Lee, and Colleana Young sued Reese Pfeiffer, Fruen & Pfeiffer LLP, Michael Fruen, and M Fruen Properties LLC. The plaintiffs asserted claims under the Fair Housing Act, the Minnesota Human Rights Act, and for negligent supervision.

Michael Fruen filed two motions to dismiss the original complaint. The plaintiffs later sought permission to amend their complaint. Magistrate Judge Katherine M. Menendez granted that request in part and denied it in part, allowing the plaintiffs to make the requested changes except for a claim seeking to pierce the corporate veil. The plaintiffs then filed an amended complaint containing additional factual allegations and new exhibits.

Court’s Analysis

The court explained that an amended complaint replaces the original complaint and generally removes the original complaint’s legal effect. When a plaintiff files an amended complaint while a motion to dismiss is pending, the motion ordinarily becomes moot, meaning there is no longer a live dispute for the court to decide on that motion. Because Michael Fruen’s motions challenged the original complaint, the court found them moot.

Disposition

The court denied as moot Michael Fruen’s motions to dismiss, identified as Docket Nos. 45 and 64. It also canceled the July 17, 2020 hearing on those motions. The order did not resolve whether the plaintiffs’ underlying claims were legally sufficient or meritorious.