Sorenson v. State of Minnesota

Background

Cherrity Honesty-Alexis Meranelli, identified in the caption as Eric M. Sorenson and also known as Cherrity Honesty-Alexis Meranelli, asked for permission to file an early dispositive motion concerning her claim under the Americans with Disabilities Act. A dispositive motion is a motion seeking a ruling that could resolve a claim or case, including a motion for summary judgment. Summary judgment asks the court to rule without a trial when the evidence shows there is no genuine dispute requiring a trial.

The scheduling order set July 31, 2022, as the deadline for completing fact discovery and September 30, 2022, as the deadline for filing dispositive motions. It instructed the parties to seek the district judge’s permission before filing early or piecemeal dispositive motions.

Meranelli stated that, after gallbladder-removal surgery, she needed to use the restroom nearly every half hour and immediately when urges persisted. She alleged that policies at the Minnesota Sex Offender Program facility prevented her from leaving scheduled programming to use the restroom and then returning. She said she was disciplined, barred from returning, or both, when she left programming.

Parties’ Positions

Meranelli discussed the legal basis for her Americans with Disabilities Act claim and submitted a declaration describing her condition and the effect of the programming policies. The defendants opposed permission to file the motion early. They argued that discovery would remain open for several months, that they would need additional discovery to respond, and that early motion practice could lead to multiple rounds of briefing and increased costs.

The defendants also argued that Meranelli failed to comply with local procedures requiring a meet-and-confer before filing most motions and a separate legal memorandum supporting the motion.

Court’s Analysis

Judge Menendez concluded that Meranelli had not shown that early summary-judgment practice would be efficient. Discovery had only just begun, Meranelli had not yet obtained discovery relevant to her claims or the defendants’ defenses, and the record would therefore be incomplete. The court also found that an early motion could require consideration of a request by the defendants for more time or additional discovery under Federal Rule of Civil Procedure 56(d), followed by another round of summary-judgment proceedings later.

The court expressly did not comment on the possible outcome of a future summary-judgment motion supported by the evidence Meranelli had submitted. It therefore did not decide the merits of her Americans with Disabilities Act claim.

The court did not base its decision on the defendants’ local-rule objections. It stated that the lack of a separate memorandum was not a reasonable basis for denying relief because the declaration gave the defendants enough information to respond. The court nevertheless emphasized that Meranelli should comply with local rules in the future and that both sides must meet and confer before filing future motions.

Disposition

The court denied without prejudice Meranelli’s Motion for Leave to File Dispositive Motion and Notice. The court stated that circumstances could change and make early dispositive motion practice appropriate later.