Schaffer v. Chauvin
- Susan Nelson
- 0:20-cv-01577
- U.S. District Court · District of Minnesota
- 4
In Schaffer v. Chauvin, Judge Nelson ordered briefing on whether Minnesota law requires court approval of the settlement’s distribution.
The plaintiff, the defendants, and the settlement proceeds were affected procedurally; the court did not decide whether approval was required or how the proceeds should be distributed.
What happened
In Schaffer v. Chauvin, the plaintiff’s lawyer asked whether the federal court or a magistrate judge would decide how settlement proceeds should be distributed. The plaintiff argued that Minnesota’s wrongful-death statute and court rule required the court to follow specific approval and distribution procedures.
The court explained that it was unclear whether the complaint asserted a Minnesota wrongful-death claim in addition to its claims under a federal civil-rights law. The complaint’s three counts alleged civil-rights violations, including Fourth Amendment violations and claims against the City of Minneapolis, while its request for relief referred to federal law rather than Minnesota’s wrongful-death statute.
Judge Nelson ordered the parties to submit briefs on whether the settlement and distribution of its proceeds must receive court approval under Minnesota law. The order did not decide that question or determine how the proceeds should be distributed.
The detailed version
- Schaffer v. Chauvin · No. 0:20-cv-01577
- Susan Nelson
- Apr. 9, 2021
Background
The plaintiff, Kaarin Nelson Schaffer, is identified in the caption as trustee for the next of kin of George P. Floyd, Jr., deceased. The defendants are Derek Chauvin, Tou Thao, Thomas Lane, J. Alexander Kueng, each sued individually as a Minneapolis police officer, and the City of Minneapolis.
After the parties reached a settlement, the plaintiff’s counsel asked whether the court would itself consider distribution of the settlement proceeds under Minnesota’s wrongful-death statute or refer that issue to a magistrate judge. The plaintiff’s position was that the court had to follow Minnesota Statutes section 573.02 and Minnesota General Rule of Practice 144.05.
Section 573.02 provides that a wrongful-death recovery benefits the surviving spouse and next of kin in proportion to their separate financial losses. It also directs the court to determine those losses and order distribution. Rule 144.05 establishes a procedure for a trustee for the decedent’s next of kin to ask the court to approve a settlement and distribute the proceeds.
Claims and issue
The court stated that federal courts generally follow those Minnesota procedures when a plaintiff brings claims under both 42 U.S.C. § 1983, a federal civil-rights statute, and Minnesota’s wrongful-death statute. The court noted that it was unclear whether those procedures are required when the plaintiff brings only § 1983 claims.
The complaint contained three counts. Count I alleged § 1983 violations of the Fourth Amendment. Count II alleged a § 1983 claim under Monell v. Department of Social Services of City of New York. Count III alleged a § 1983 claim under City of Canton v. Harris. Each count also stated that the alleged conduct constituted wrongful acts and omissions for purposes of Minnesota Statutes section 573.02, subdivision 1. But the complaint’s request for relief sought remedies under 42 U.S.C. § 1988, not under Minnesota’s wrongful-death statute.
Order
Because the complaint did not clearly state a claim or seek relief under Minnesota’s wrongful-death statute, the court did not determine whether section 573.02 and Rule 144.05 governed judicial approval and distribution of the settlement. Instead, the court ordered briefing on whether the settlement and distribution of settlement proceeds must be approved by the court under the wrongful-death statute. The plaintiff’s memorandum was due April 23, 2021, and the defendants’ responsive memoranda, if any, were due May 7, 2021.
The order therefore resolved only the briefing process. It did not decide whether court approval was legally required, approve or reject the settlement, or determine the distribution of settlement proceeds.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.