Fredin v. Middlecamp

Background

Brock Fredin represented himself in two related cases against Lindsey Middlecamp, and against Grace Elizabeth Miller and Catherine Marie Schaefer. The district court reviewed Fredin’s objections to Magistrate Judge Bowbeer’s April 24, 2020 orders.

Those orders denied Fredin’s third request to reopen discovery and extend the deadline for nondispositive motions. Magistrate Judge Bowbeer found that Fredin had repeatedly disregarded the pretrial scheduling order and warned that another request to reopen discovery could result in sanctions. She also generally denied Fredin’s request for sanctions against the defendants but directed them to respond to Fredin’s claim that information he produced under protective orders had been improperly used or disclosed.

After receiving the defendants’ response, Magistrate Judge Bowbeer found that Fredin had not marked any of the discovery information as confidential under the protective orders. She therefore concluded that the defendants could not have violated those orders by using or disclosing the information and found Fredin’s sanctions motion frivolous. The opinion also states that, in a later order, she ordered Fredin to pay $1,260 in attorney’s fees to defense counsel after giving him an opportunity to explain why he should not be required to pay the defendants’ reasonable expenses.

Fredin’s objections

Fredin argued that a six-month delay in the trial date created a new reason to continue discovery. He also argued that sanctions and additional discovery were needed to investigate what he described as an ongoing stalking campaign. He relied on an anonymous email sent to the defendants’ own counsel that included a link to a published Minnesota Court of Appeals decision, which Fredin claimed supported his allegations of continuing wrongdoing.

Court’s analysis

The district court applied the deferential standard for reviewing a magistrate judge’s ruling on a nondispositive matter. Under that standard, the court could set aside the ruling only if it was clearly erroneous or contrary to law. The court found no clear error in the April 24 orders.

The court agreed that Fredin had not shown good cause to reopen discovery and that changes to the pretrial scheduling orders did not justify doing so. It also rejected Fredin’s request to investigate alleged protective-order violations, finding no error in the magistrate judge’s conclusion that his allegations lacked merit and that his sanctions motion was frivolous. The court further found that the alleged new evidence concerning stalking did not support additional discovery or sanctions.

Disposition

The court overruled Fredin’s objections to the April 24, 2020 orders in both cases and affirmed those orders. The court reiterated the warning that continued attempts by Fredin to reopen discovery could result in sanctions.