Hartmann v. Schauer

Background

Michael and Diane Hartmann operated a farm on property in Sibley County, Minnesota. Their property was in a county shore-land district. They built a home and septic system in 1991, when the system complied with the zoning codes then in effect.

After the Hartmanns modified a pole shed in 2010, Sibley County Environmental Services notified them that they needed a zoning permit and would have to show that their septic system complied with current county ordinances. One ordinance required a nonconforming sewage system to be upgraded when a permit or variance was needed for an improvement or use of the property.

County Attorney David E. Schauer asked the Hartmanns to apply for a permit and arrange a review of the septic system. After they did not comply, Schauer filed a civil enforcement action against Michael Hartmann. In 2012, Michael entered into a settlement stipulation with Sibley County requiring replacement of the septic system within three years. A state court entered the stipulation as an order and retained jurisdiction to enforce it.

The Hartmanns did not replace the system. The state court later issued additional orders requiring them to arrange for its design, installation, and completion. The state proceedings included multiple arrest warrants and additional enforcement proceedings. In 2020, the Hartmanns sought to nullify the settlement agreement in state court.

Michael had also previously filed a federal lawsuit arising from the state enforcement actions. The federal court granted Schauer’s motion for judgment on the pleadings, dismissing some claims with prejudice and others without prejudice. That court concluded that the settlement was in effect through a state court order and that the federal court lacked jurisdiction to invalidate the state order.

Michael died in January 2022. Diane remained a plaintiff, so the court proceeded to address the motion to dismiss.

Claims and Motion to Dismiss

The Hartmanns filed this action against Schauer, in both his official and individual capacities, and the County of Sibley. They sought damages and injunctive relief based on the state-court enforcement proceedings and settlement. They asserted several constitutional claims, including claims alleging unequal enforcement.

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which asks whether the complaint alleges enough facts to state a legally plausible claim for relief.

Court’s Analysis

Absolute immunity. The court held that Schauer’s filing of the civil enforcement action was a function similar to that of a prosecutor because he acted as county attorney to obtain compliance with local zoning ordinances. The court therefore held that absolute immunity barred the Hartmanns’ damages claims against Schauer. The court also explained that this immunity did not extend to claims seeking declaratory or injunctive relief, so it did not independently bar the Hartmanns’ request for an injunction.

County liability. The court applied the rule from Monell v. Department of Social Services that a municipality can be liable for an employee’s unconstitutional conduct only when a municipal policy or custom was the moving force behind the violation. The court found that the complaint did not identify a policy or custom that contributed to the alleged constitutional violation. It also found that the Hartmanns had not alleged facts showing that the claimed selective enforcement was itself a constitutional violation. The court therefore held that the claims for monetary and injunctive relief against the County of Sibley failed.

Federal jurisdiction over the requested injunction. The court then considered the remaining claim for injunctive relief against Schauer. The Hartmanns asked the federal court to order defendants to stop prosecuting and persecuting them in connection with the matter. The court applied the Rooker-Feldman doctrine, which prevents federal district courts from reviewing or rejecting state-court judgments. It held that the Hartmanns’ requested relief would require the federal court to allow them to withdraw from the 2012 settlement, which state courts had upheld and enforced. Their constitutional claims were therefore inseparably connected to the state-court enforcement proceedings, and the federal court lacked jurisdiction over them.

Disposition

Judge John R. Tunheim granted Defendants’ Motion to Dismiss. The court ordered that the action be dismissed without prejudice and directed that judgment be entered accordingly.