Sacks v. University of Minnesota

Background

Michael Sacks, Christopher Jensen, Brent Cary, Benjamin Cole, Kelly Gee, Frank Pietrangelo, John Doe A, and Jeffrey Walker alleged that Thomas Adrahtas sexually abused them while he was a hockey coach. The alleged abuse occurred between 1984 and 2003, when the plaintiffs were in their teens or early twenties. The plaintiffs sought damages and other remedies from Adrahtas and from the University of Minnesota, the Board of Regents of the University of Minnesota, USA Hockey, Inc., and Amateur Hockey Association Illinois, Inc., which the opinion refers to as Hockey Illinois.

The plaintiffs asserted three federal claims: two claims under 42 U.S.C. § 1983 and one claim under Title IX. They also asserted twenty-eight state-law claims. The defendants moved to dismiss the amended complaint, and the plaintiffs sought permission to file a second amended complaint.

Jurisdictional rulings

The court held that the plaintiffs’ § 1983 claims against the University and the Board of Regents were not substantial federal claims because binding precedent foreclosed treating the University or the Board as a suable “person” under § 1983. Counts Two and Three were therefore dismissed as to the University and the Board for lack of subject-matter jurisdiction.

The court also held that Cary, Cole, and Gee could not assert Title IX claims against the University based on the allegations in the amended complaint. Their alleged abuse occurred after Adrahtas’s University employment ended, and the complaint did not allege that they attended, visited, or considered attending the University. Their portion of Count One was dismissed for lack of subject-matter jurisdiction.

The court found no supplemental jurisdiction over the state-law claims against USA Hockey and Hockey Illinois. Supplemental jurisdiction is a federal court’s authority to hear related state-law claims alongside federal claims. The court found no discernible factual overlap between those claims and the remaining federal claims, which concerned Adrahtas’s conduct and the University’s actions during his University employment. Counts Seventeen through Twenty-Nine were dismissed as to USA Hockey and Hockey Illinois for lack of subject-matter or supplemental jurisdiction.

The court also held that Minnesota lacked personal jurisdiction over Adrahtas for claims brought by Jensen, Walker, Cary, Cole, and Gee. Personal jurisdiction means the court’s authority over a particular defendant in connection with the claims. The court found that the alleged assaults involving those plaintiffs occurred in Illinois or Massachusetts and lacked a sufficient connection to Minnesota. Adrahtas’s past work and contacts with Minnesota did not establish the required connection between Minnesota and those claims.

Statute of limitations and federal claims

The court held that the federal claims were untimely. It applied Minnesota’s six-year general personal-injury limitations period to the Title IX and § 1983 claims. The court concluded that the claims accrued no later than 1985, when the alleged assaults occurred or when the University allegedly learned of them, so the six-year period expired by the summer of 1991.

The court rejected the plaintiffs’ arguments that Minnesota’s Child Victims Act, repressed memories, or fraudulent concealment delayed the federal claims. It found that federal law governed when the federal claims accrued, that the plaintiffs did not present a valid tolling argument for those claims, and that the complaint did not adequately plead fraudulent concealment. The court also stated that, even apart from timeliness, certain federal claims would fail under the rule requiring a complaint to state a legally sufficient claim.

Disposition of the motions

The court granted Adrahtas’s motion to dismiss. Claims brought against Adrahtas by Jensen, Walker, Cary, Cole, and Gee were dismissed without prejudice for lack of personal jurisdiction. Count Two against Adrahtas was dismissed with prejudice under Rule 12(b)(6), the rule governing failure to state a claim.

The court granted USA Hockey’s motion to dismiss and dismissed the plaintiffs’ state-law claims against USA Hockey in Counts Seventeen through Twenty-Nine without prejudice for lack of subject-matter or supplemental jurisdiction. It granted Hockey Illinois’s motion on the same basis and with the same disposition.

The court granted the University and the Board of Regents’ motion to dismiss. Count One, to the extent brought by Cary, Cole, and Gee, and Counts Two and Three were dismissed without prejudice for lack of subject-matter jurisdiction. Count One, to the extent brought by Michael Sacks, Jensen, Pietrangelo, John Doe A, and Walker, was dismissed with prejudice under Rule 12(b)(6).

The court declined to exercise supplemental jurisdiction over the remaining state-law claims against the University and/or Adrahtas. Counts Four through Nineteen and Thirty through Thirty-One were dismissed without prejudice. The court denied the plaintiffs’ motion for leave to file a second amended complaint because the proposed amendments would not cure the jurisdictional, personal-jurisdiction, or statute-of-limitations problems. The action was dismissed, and judgment was ordered entered.