Favors v. Nicollet County District Court

Background

Joseph Anthony Favors, proceeding without a lawyer, sued the Nicollet County District Court, which the opinion identifies as a Minnesota state court. He alleged that the court violated his federal constitutional rights by failing to act on two lawsuits he had filed. He also asserted a state-law negligence claim and sought damages on both claims.

Magistrate Judge Elizabeth Cowan Wright recommended dismissing Favors’s federal claims, declining to exercise supplemental jurisdiction over the negligence claim, and denying his application to proceed without prepaying fees or costs. Favors objected to the recommendation and moved for permission to file an amended complaint.

Federal Claims and Proposed Amendment

Favors did not object to the conclusion that his federal damages claim under 42 U.S.C. § 1983 failed. The court explained that the Nicollet County District Court was an arm of the state and therefore was not a “person” subject to a damages claim under § 1983. The court also stated that a non-consenting state is protected from damages claims by the Eleventh Amendment.

Favors proposed naming the chief judge of the Nicollet County District Court and a court clerk as defendants, and sought declaratory and injunctive relief. The court denied leave to amend because the proposed amendments would be futile. It stated that the judge and clerk would be immune from damages claims for actions taken in their judicial capacities. The court further stated that § 1983 barred injunctive relief against a judicial officer unless a declaratory decree had been violated or declaratory relief was unavailable, neither of which Favors alleged.

The court also found that Favors had not plausibly alleged a basis for declaratory relief. It explained that the available declaratory relief would need to address future conduct, while Favors’s allegations concerned past conduct. The court noted that Minnesota law provides a possible state-court mandamus remedy when a lower court refuses to exercise clearly required judicial power, and concluded that it was better to let the matter proceed in state court.

Negligence Claim and Order

After the federal claims were dismissed, the court concluded that judicial economy, convenience, fairness, and respect for state courts supported declining supplemental jurisdiction over Favors’s state-law negligence claim. The court therefore stated that it was appropriate to dismiss that claim as well.

Judge Eric C. Tostrud overruled Favors’s objections and accepted the Report and Recommendation. The court denied Favors’s motion for leave to file an amended complaint, dismissed the action without prejudice under 28 U.S.C. § 1915(e)(2)(B), and denied as moot his application to proceed in district court without prepaying fees or costs.