Peterson-Rojas v. Dakota County

Background

Maija Peterson-Rojas sued Dakota County, John Galloway, and Letty Galloway. She alleged that, while employed by Dakota County as a juvenile probation officer, she experienced sex discrimination, sexual harassment, and retaliation under Title VII and the Minnesota Human Rights Act. She also asserted defamation and tortious interference with prospective economic advantage under Minnesota law. She alleged that John Galloway harassed her and made or circulated false accusations, that Letty Galloway made false reports about her, and that Dakota County failed to stop the conduct or defamed her through statements about investigations and administrative leave.

Dakota County investigated allegations that Peterson-Rojas had sexual contact with a minor and sought to buy drugs from a minor. She was placed on paid administrative leave during the investigations, kept her pay, title, and benefits, and was returned to her prior position after the allegations were found to be unsubstantiated. She later left Dakota County for a position with Hennepin County. The Galloways also brought a crossclaim against Dakota County under Minnesota Statutes section 260E.35, alleging that the county unlawfully disclosed Letty Galloway’s identity as a reporter of alleged maltreatment. The court had previously dismissed the Galloways’ indemnification crossclaim with prejudice and allowed the disclosure-related crossclaim to proceed. Peterson-Rojas withdrew her Minnesota Data Practices Act claim.

Summary-judgment standard

Summary judgment is a decision without a trial when the record shows no genuine dispute over a fact that could affect the result and the moving party is entitled to judgment under the law. The court views the evidence favorably to the party opposing the motion, but that party must identify specific evidence supporting each essential part of a claim.

Employment claims against Dakota County

The court granted summary judgment on the sex-discrimination and retaliation claims. The parties agreed to use the burden-shifting framework from McDonnell Douglas Corp. v. Green because there was no direct evidence of discrimination or retaliation. The court focused on whether Peterson-Rojas’s paid administrative leave was an adverse employment action—an employment decision causing legally significant harm. It held that paid leave during an investigation was not an adverse employment action here because Peterson-Rojas retained her pay, title, and benefits and was restored to her position after the investigations. Her distress during the investigations did not change that conclusion.

The court also granted summary judgment on the hostile-work-environment claim. It assumed, without deciding, that the alleged harassment was based on sex, but found insufficient evidence that Dakota County knew Galloway was responsible for the alleged misinformation campaign and failed to act. The county investigated the accusations, rejected an earlier accusation about Peterson-Rojas, warned Galloway not to repeat it, and could not definitively determine during the later investigations that Galloway was responsible. The court stated that the claim might have been viable if the county had known Galloway was behind the allegations and failed to act, but concluded that the record did not establish those facts.

Defamation claims against Dakota County

The court granted summary judgment on Peterson-Rojas’s defamation claims against Dakota County. She identified statements made at a staff meeting, in a staff memorandum, and in connection with her second administrative leave. The court held that the statements were true because they described the allegations, the investigations, and the reason for placing her on leave; they did not state that she had committed the alleged misconduct. The memorandum also stated that she had been exonerated. The court explained that truth is a complete defense to defamation.

The court also rejected Peterson-Rojas’s theory that Dakota County was legally responsible for John Galloway’s alleged defamatory statements. She did not identify the statements specifically or show that they were made within the scope of his employment. The court treated that issue as conceded because she did not address it in her briefing.

Tortious-interference claim against Dakota County

The court granted summary judgment on the claim that Dakota County interfered with Peterson-Rojas’s prospective economic advantage. The court held that she had not shown wrongful conduct by Dakota County and had not specifically identified the third party that was the source of the expected economic relationship. It also noted that she obtained other work with Hennepin County after the investigations and favorable performance reviews, which did not support her claim of damages or unemployability. The court said that events involving her later employment were outside the scope of this case.

Letty Galloway’s disclosure-related crossclaim

The court granted Dakota County’s motion for summary judgment against Letty Galloway on her claim under Minnesota Statutes section 260E.35. That law prohibits a person investigating alleged maltreatment of a minor from intentionally disclosing the reporter’s identity and allows civil liability for violations. The court found that the record did not establish who disclosed Letty Galloway’s identity or the circumstances of the disclosure. Without those facts, the court held that neither it nor a jury could determine whether the statute had been violated.

Claims against John and Letty Galloway

The court granted the Galloways’ motion for summary judgment on Peterson-Rojas’s claims against them.

For the defamation claim against John Galloway, the court considered only the two statements specifically identified in the complaint. It found no admissible evidence that the alleged recipients heard the first statement. As to the second statement involving an envelope containing allegedly fabricated text-message screenshots, the record did not establish that John Galloway was connected to the envelope or its contents, and there was no supporting testimony from the alleged recipients. The court therefore held that no genuine factual dispute prevented summary judgment.

For the defamation claim against Letty Galloway, the court found no credible evidence supporting one alleged statement. It found another statement was not actionable because the recipient understood it to be false and therefore it did not damage Peterson-Rojas’s reputation. As to Letty’s report to a county employee about alleged sexual misconduct and an attempt to buy drugs from a minor, the court concluded that the report was protected by qualified privilege. Qualified privilege is a legal protection for statements made in a proper setting, for a proper purpose, in good faith, and with reasonable grounds. The court found insufficient evidence that Letty knew the allegations were false or acted only to harm Peterson-Rojas.

The court also granted summary judgment to the Galloways on the tortious-interference claims for the same reasons it rejected the corresponding claim against Dakota County.

Disposition

The order granted Dakota County’s motion for summary judgment against Letty Galloway, granted Dakota County’s motion for summary judgment against Peterson-Rojas, and granted the Galloways’ motion for summary judgment. The case was dismissed with prejudice, meaning the court barred refiling the dismissed case.