Greene v. Meeker County Department of Human Services

Background

Kyle Richard Greene and Krystle Lynn Greene represented themselves in a case concerning the suspension of Kyle’s driver’s license. They alleged that the suspension violated the United States Constitution and the Americans with Disabilities Act. Their proposed second amended complaint also sought to add a claim under the Racketeer Influenced and Corrupt Organizations Act and to add the Meeker County District Court and the Minnesota Court of Appeals as defendants.

The opinion notes that the Greenes identified the defendant as the “Meeker County Department of Human Services (DHS),” but Meeker County has no department with that name. The opinion states that the relevant department is Meeker County Social Services. The Greenes alleged that Kyle’s license was suspended after the Minnesota Department of Public Safety was notified that he had not complied with a payment agreement. They also alleged that no such payment agreement existed and challenged events involving Kyle’s child-support proceeding and his attempt to proceed without paying appellate filing fees.

Motions and legal standard

The Greenes moved for permission to file a second amended complaint. The defendant moved to dismiss the operative amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. The court considered whether the proposed amendment would be futile—that is, whether the proposed complaint could survive a motion to dismiss. The court accepted the proposed complaint’s factual allegations as true for this analysis but required the allegations to make the asserted claims plausible rather than speculative.

Reasons for denying leave to amend

The court concluded that the proposed claims against the Meeker County District Court and the Minnesota Court of Appeals were barred by the state’s immunity from suit in federal court under the Eleventh Amendment. The court therefore found those proposed claims futile.

The court also concluded that Meeker County Social Services was not an entity that could be sued. Under Minnesota law, a county may sue and be sued, but the opinion states that county human-services departments are not separate suable entities. The claims against Social Services therefore could not proceed against that defendant.

The court added that, even if Social Services could be sued, the proposed claims would fail on their merits. The proposed Racketeer Influenced and Corrupt Organizations Act claim did not adequately allege a pattern of racketeering activity, the required connection to an enterprise, or mail fraud carried out as part of a scheme to defraud. The court also noted that the claim was not pleaded with the required specificity.

The Americans with Disabilities Act claim did not plausibly allege that Social Services denied the Greenes services or that any denial or license suspension occurred because of their disabilities. The proposed claim concerning Kyle’s alleged constitutional right to earn a living was treated as abandoned to the extent it was a substantive due-process claim. To the extent the Greenes intended a procedural-due-process claim, the court found the allegations insufficient. The complaint alleged that Kyle received a January 2022 notice about his license but did not plausibly explain what additional process was required or constitutionally inadequate.

The court also rejected the proposed racial-discrimination claim. It found that the allegations did not plausibly show discriminatory intent, selective treatment compared with similarly situated people, or an impaired contractual relationship required for a claim under 42 U.S.C. § 1981.

Disposition

The court DENIED Kyle Richard Greene and Krystle Lynn Greene’s Motion for Leave to Amend. It GRANTED the defendant’s Motion to Dismiss for Failure to State a Claim and DISMISSED WITHOUT PREJUDICE the Greenes’ Amended Complaint for failure to state a claim upon which relief may be granted. Judge Eric C. Tostrud ordered that judgment be entered accordingly.