Hansmeier v. MacLaughlin

Background

Paul R. Hansmeier, proceeding without a lawyer, sued David MacLaughlin, W. Anders Folk, and Portland Corporate Center, LLC. He challenged the constitutionality of federal mail-fraud, wire-fraud, and extortion statutes as applied to proposed copyright-enforcement and Americans with Disabilities Act enforcement activities. The court stated that Hansmeier had filed at least sixteen related actions in the District of Minnesota and that it had stayed other active cases while resolving the motion in this case.

Claims Against the Federal Defendants

The federal defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally plausible claim. The court applied res judicata, a doctrine that prevents a party from relitigating issues already litigated and decided. The court described this doctrine as including issue preclusion, which bars relitigation of an issue when the parties or their legal equivalents were involved before, the issue is the same, it was actually litigated, a final and valid judgment decided it, and deciding it was necessary to that judgment.

The court found that all five requirements were satisfied based on an earlier case before Judge James Boasberg. It determined that the federal defendants were legally connected to the Attorney General who was sued in that earlier case, that the issue was the same despite differences in wording, and that the earlier dismissal for failure to state a plausible claim was final and valid for issue-preclusion purposes. The court also found a separate basis for issue preclusion in several earlier District of Minnesota cases. It concluded that Hansmeier’s prior voluntary dismissals, considered together under Federal Rule of Civil Procedure 41, supplied a final and valid judgment for this purpose.

The court therefore granted the Federal Defendants’ Motion to Dismiss and, in the order, dismissed Hansmeier’s complaint against the federal defendants with prejudice. The court did not address the federal defendants’ other stated grounds for dismissal.

Portland Corporate Center, LLC

The court separately ruled that Hansmeier had not properly served Portland under Federal Rule of Civil Procedure 4. Because the complaint had been filed in May 2021 and Portland still had not been served by the requested March 1, 2022 deadline, the court dismissed the complaint against Portland without prejudice under Rule 4(m).

Filing Restrictions

The court granted the federal defendants’ request for filing restrictions. Without prior written approval from the Chief Judge of the District of Minnesota, Hansmeier may not file new lawsuits, pleadings, or other papers in that district concerning a copyright-infringement action or private enforcement action under the Americans with Disabilities Act against the U.S. Attorney General, former Acting U.S. Attorney Folk, any future United States Attorney for the District of Minnesota, Assistant U.S. Attorney MacLaughlin, former U.S. Attorney Luger, or the U.S. Attorney’s Office for the District of Minnesota. The restrictions also apply to actions removed to that district that meet the stated description; the order directs immediate closure and dismissal without prejudice of such matters.

Other Orders

The court denied as moot the motion to consolidate cases, Hansmeier’s motion to strike, and his motion to extend the service deadline. It lifted the stay in thirteen listed related cases and dismissed each of those cases with prejudice. It also denied all pending motions in those cases as moot and directed that judgment be entered.