Nordgren v. Hennepin County

Background

Christine M. Nordgren brought federal civil-rights and state-law claims against Jodi Harpstead, Hennepin County and County officers and employees, Nystrom & Associates, Ltd. and its employees, and Craig Rice. The claims arose from a Minnesota state court’s decision to terminate Nordgren’s parental rights.

On August 25, 2021, the court granted the County Defendants’, Harpstead’s, and Rice’s motions to dismiss and granted the Nystrom Defendants’ motion for judgment on the pleadings. The court therefore dismissed Nordgren’s action in its entirety. The opinion states that the earlier order concluded, among other things, that the court lacked jurisdiction over some claims under the Rooker-Feldman doctrine, that a “penalty” exception did not apply to Nordgren’s Fifth Amendment claims, and that she had not plausibly pleaded claims under 42 U.S.C. § 1983.

Nordgren’s Motion

Nordgren filed a motion under Federal Rule of Civil Procedure 59(e), asking the court to alter or amend the judgment and allow her to file an amended pleading. She argued that the court had made manifest errors of fact and law in its earlier order. The court noted that Nordgren’s requested amendment would revive the dismissed action and effectively reverse the earlier rulings on the defendants’ motions.

The court also explained that Nordgren’s earlier request to amend had not been made through a formal motion and was not accompanied by proposed amended pleadings, as required by the District of Minnesota’s local rule and controlling appellate decisions. The earlier order had denied leave to amend because amendment would have been futile.

Court’s Analysis

The court construed Nordgren’s motion according to its substance rather than its title. Because she repeated arguments already considered and sought to reverse the earlier order, the court treated the filing as a motion for reconsideration.

Under District of Minnesota Local Rule 7.1(j), a party may not file a motion for reconsideration without first showing compelling circumstances and obtaining the court’s permission. Nordgren had not requested that permission and had not complied with the local rule. The court therefore denied her motion.

Disposition

The court ordered that Nordgren’s Motion to Alter or Amend Judgment was DENIED. The court also declined to impose the sanctions requested by Rice, finding sanctions unnecessary at that time. This order addressed Nordgren’s request for reconsideration and amendment; it did not reopen or otherwise change the earlier dismissal of the action.