Maddox v. Zera

Background

Angela Maddox, representing herself, sued Richard Zera, Jennifer Hauff, Juliet Tatsumi, Hennepin County Medical Center, and Hennepin Faculty Associates. She alleged that Dr. Richard Zera performed a more invasive procedure on her left breast than the procedure to which she had consented. She also challenged rulings from her Minnesota state-court case.

The federal court had previously dismissed Maddox’s complaint without prejudice for lack of subject-matter jurisdiction. It concluded that the Rooker-Feldman doctrine barred the federal court from reviewing the state-court decisions and that Maddox had not alleged another basis for federal jurisdiction. The court had also previously denied her earlier requests for relief under Rules 59 and 60.

Motions and petitions

Maddox then filed another motion for relief under Federal Rule of Civil Procedure 60(b), an objection to a report and recommendation that the court had already adopted, a petition seeking intervention by the United States, another Rule 60 request, a motion to stay the judgment during an appeal, an application to proceed in forma pauperis on appeal, and a petition for permission to appeal the Minnesota Supreme Court’s denial of further review.

The court denied the new Rule 60(b) motion because it repeated the earlier motion with only a minor change and did not identify new grounds, evidence, or arguments supporting extraordinary relief. The court denied Maddox’s objection because the recommendation had already been adopted and the objection was untimely and moot. The court also denied the petition for intervention because Maddox did not challenge the constitutionality of an act of Congress, which is required for intervention under 28 U.S.C. § 2403(a).

The court denied the motion to stay the judgment pending appeal. It found that Maddox was unlikely to succeed on the merits and that she would not suffer irreparable harm because the monetary damages she sought would remain available if she succeeded on appeal. The court granted her application to proceed in forma pauperis on appeal, meaning she could pursue the appeal without paying the required fees and costs because she had shown that she could not afford them. Finally, the court denied her petition for permission to appeal the Minnesota Supreme Court’s decision because this federal district court could not review that state-court decision.

Disposition

The order denied Maddox’s Rule 60(b) motion; denied her objection to the report and recommendation; denied her petition for intervention, Rule 60 relief, and a stay pending appeal; granted her application to proceed in forma pauperis on appeal; and denied her petition for permission to appeal. Chief Judge John R. Tunheim emphasized that the federal district court could not oversee or overturn the Minnesota state courts’ actions. The order addressed jurisdiction and requests for post-judgment relief rather than deciding whether Maddox’s allegations about the medical procedure were true.