Kedrowski v. Richards

Background

David M. Kedrowski, proceeding without a lawyer, sued Elizabeth Richards, Loretta Frederick, Liberty Aldrich, Violence Free Minnesota, the Battered Women’s Justice Project, and The New York Fund. The complaint asserted claims under 42 U.S.C. §§ 1983 and 1985(3), alleging that the defendants—private individuals and organizations advocating for domestic-abuse victims—worked with officials of Minnesota’s Fourth Judicial District through grants from the United States Department of Justice’s Office on Violence Against Women.

Kedrowski alleged that the defendants helped create and administer court procedures, training, and decision-making tools that favored women alleging domestic abuse and harmed men accused of domestic abuse. He alleged that these activities affected the handling of his marital-dissolution case, including custody and parenting-time proceedings, and violated his rights to an independent and impartial tribunal, equal protection, procedural due process, and substantive due process. He also asserted claims for conspiracy, failure to train, and failure to supervise, seeking compensatory and punitive damages and other relief.

The opinion notes that the parties had already stipulated to the dismissal with prejudice of Elizabeth Richards and Violence Free Minnesota.

Jurisdictional rulings

The defendants argued that the court lacked subject-matter jurisdiction under the Rooker-Feldman doctrine. That doctrine generally prevents a federal district court from acting as an appeals court over a state-court judgment. The court rejected that argument. It reasoned that Kedrowski sought damages from the defendants for allegedly biased procedures and conduct, rather than direct review, invalidation, or reversal of the state court’s orders. The court therefore held that subject-matter jurisdiction existed.

Liberty Aldrich and The New York Fund separately argued that the court lacked personal jurisdiction over them. The court rejected that argument too. It concluded that Kedrowski had alleged sufficient contacts with Minnesota, including Aldrich’s alleged work with the Fourth Judicial District, participation in court-management meetings, involvement in court policies and procedures, and communications concerning the proceedings. The court held that these allegations supported specific personal jurisdiction over Aldrich and The New York Fund.

Failure to state a claim

The defendants moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not allege enough facts to support a legally plausible claim. The court held that Kedrowski plausibly alleged that the private defendants acted jointly with state officials for purposes of the “under color of state law” requirement applicable to his claims under §§ 1983 and 1985(3). The court relied on allegations that defendants exercised influence over court procedures, trained and advised the referee in Kedrowski’s case, participated in court-management activities, and helped implement court policies.

The court nevertheless found that the pleaded claims failed for other reasons:

- Counts I and II—independent and fair tribunal: The court treated these allegations as due-process claims and held that they failed for the same reasons as the procedural- and substantive-due-process claims. - Count III—equal protection: The court held that Kedrowski did not plausibly allege membership in a protected class. Being accused of domestic abuse, or being a man accused of domestic abuse, was not a protected class under the authorities the court applied. - Count IV—procedural due process: Even accepting the allegation that defendants caused bias in the state proceedings, the court held that Kedrowski had constitutionally sufficient procedures available because he had exercised appellate rights to challenge the alleged bias. - Count V—constitutional conspiracy under § 1985(3): This claim failed because Kedrowski did not plausibly allege membership in a protected class. - Counts VI and VII—failure to train and failure to supervise: The court held that Kedrowski did not plausibly allege a constitutional violation or the deliberate indifference required for these claims. The allegations that the organizations knew of unconstitutional conduct and failed to train or supervise were conclusory. - Count VIII—substantive due process: The court held that the complaint did not allege conduct sufficiently extreme to “shock the conscience,” as required for this type of claim.

Disposition

The court ordered that the motion to dismiss filed by Loretta Frederick and the Battered Women’s Justice Project was GRANTED under Rule 12(b)(6). The motion to dismiss filed by Elizabeth Richards and Violence Free Minnesota was DENIED AS MOOT because those defendants had previously been dismissed by stipulation and court order. The motion to dismiss filed by Liberty Aldrich and The New York Fund was GRANTED under Rule 12(b)(6).

The court further ordered that Kedrowski’s complaint was DISMISSED WITH PREJUDICE and directed that judgment be entered. Judge Eric C. Tostrud stated that Kedrowski would not be given an opportunity to file an amended complaint because he had already defended the original complaint and identified no additional allegations that could overcome the Rule 12(b)(6) challenge.