Peterson-Rojas v. Dakota County

Background

Maija Peterson-Rojas sued Dakota County, John Galloway, and Letty Galloway. Her complaint asserted discrimination claims under Title VII and the Minnesota Human Rights Act, defamation claims, interference-with-economic-advantage claims, and claims under the Minnesota Data Practices Act. The order addressed two motions: Peterson-Rojas’s motion for leave to amend the complaint to add punitive damages and additional defamation facts, and Dakota County’s motion for sanctions based on allegedly deficient discovery responses.

Motion to Amend

The court denied Peterson-Rojas’s motion for leave to amend. The proposed amendment included about 15 pages of additional factual allegations, but the deadline to seek factual amendments under the pretrial scheduling order had passed. Because the motion was late, the court required good cause under Federal Rule of Civil Procedure 16. The court found that Peterson-Rojas had not explained how she had tried to meet the deadline or how changing the schedule would affect other deadlines. The court also found that she had not properly met and conferred with the defendants before filing the motion.

The court separately considered the proposed punitive-damages claims. It held that punitive damages were unavailable against Dakota County for the Title VII, defamation, and interference claims. Under the Minnesota Human Rights Act, the court stated that Peterson-Rojas could request punitive damages at trial without amending the complaint, subject to the statutory cap and other requirements. As to John and Letty Galloway, the court found the proposed amendment futile because Peterson-Rojas had not alleged facts showing that they knew their allegedly defamatory statements were false or deliberately disregarded whether they were false, as required by Minnesota law.

Sanctions Motion

Dakota County argued that Peterson-Rojas’s supplemental answers to interrogatories 5, 6, 9, 10, 11, 12, and 14 remained deficient after an earlier order required complete answers. The court agreed, finding that the answers were nonresponsive and often copied allegations from the complaint or proposed amended complaint rather than answering the questions asked.

The County asked the court to recommend dismissal of Peterson-Rojas’s claims against the County. The court declined to recommend dismissal, finding that this extreme sanction was unwarranted at that time. Instead, it granted in part and denied in part the County’s motion for sanctions. The court ordered Peterson-Rojas to serve responsive answers to the seven interrogatories within 14 days and to reimburse the County’s reasonable expenses and attorneys’ fees associated with the sanctions motion. The County was ordered to submit an affidavit detailing the requested fees and expenses, and Peterson-Rojas was allowed to file objections under the schedule stated in the order.

Additional Warning and Disposition

Judge Tony N. Leung warned that failure to comply with the order or prior consistent orders could lead to further remedies, including costs, fees, limits on evidence, striking pleadings, dismissal with prejudice, or default judgment. Those consequences were listed as possible future remedies; the order did not impose them at that time. The court also stated that it made no definitive finding concerning the County’s allegation that an unauthorized person was significantly assisting Peterson-Rojas’s counsel.

The order therefore states: (1) Peterson-Rojas’s motion for leave to amend was denied; (2) Dakota County’s sanctions motion was granted in part and denied in part; and (3) Peterson-Rojas was ordered to provide the specified discovery responses and follow the fee-related deadlines.