Kaisamba-Kanneh v. Dakota County District Court

Background

Alpha L. Kaisamba-Kanneh, proceeding without a lawyer, sued the Dakota County District Court; the Minnesota Guardian ad Litem Board; Judges Kathryn Davis Messerich, Tim D. Wermager, David Lutz, Vicki Vial Taylor, and Joseph Carter; Dakota County Court Administrator Maria King; and Minnesota Guardian ad Litem Program Supervisor Melanie Sanchez. The individual defendants were sued only in their official capacities.

Kaisamba-Kanneh alleged that the defendants violated his constitutional rights during custody proceedings involving his minor child. His allegations included manipulating court records, concealing or removing a motion, making false statements in orders, showing bias, preventing a witness from being heard, searching and seizing electronic data without a warrant, and conspiring to cause an arrest. He invoked 42 U.S.C. § 1983 and cited 18 U.S.C. §§ 2071 and 241. He sought $80 million in damages.

The custody proceedings included orders awarding custody to others and, later, an October 25, 2022 order awarding sole legal and physical custody to Kaisamba-Kanneh. The opinion states that Kaisamba-Kanneh filed this federal case on October 24, 2022. Although he said he intended to file a much longer complaint and requested 60 days to do so, he did not amend the complaint or move for permission to amend it.

Defendants’ arguments

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which addresses the court’s subject-matter jurisdiction, and Rule 12(b)(6), which addresses whether a complaint states a legally sufficient claim. They argued that the Eleventh Amendment barred the damages claims against the Dakota County District Court, the Guardian ad Litem Board, and the individual defendants in their official capacities. They also argued that the criminal statutes cited by Kaisamba-Kanneh did not create private rights of action, that the judges and other officials were immune, and that the complaint lacked plausible factual allegations.

Court’s analysis

The court granted the motion under Rule 12(b)(1). It held that the Dakota County District Court and the Minnesota Guardian ad Litem Board were arms of the state and therefore protected by Eleventh Amendment immunity from damages claims. It also held that the Eleventh Amendment barred damages claims against state employees sued in their official capacities. The court found that the exception allowing certain lawsuits for prospective relief against state officials did not apply because Kaisamba-Kanneh sought damages for past conduct and did not allege an ongoing violation.

The court gave additional reasons why the complaint would fail even if jurisdiction existed. It held that 18 U.S.C. §§ 2071 and 241 are criminal statutes that do not provide private rights of action.

The court also held that the claims against the judges were barred by judicial immunity because the alleged conduct involved traditional judicial functions, including handling transcripts, motions, orders, compliance with orders, and witnesses. The court held that Court Administrator King and Guardian ad Litem Supervisor Sanchez were protected by quasi-judicial immunity because the complaint did not plausibly allege that they acted outside their roles in the judicial process.

Finally, the court held that the complaint failed to state a claim under Rule 12(b)(6). The allegations were largely conclusions and did not identify which defendant performed which act, what specific records were manipulated, how they were manipulated, or how the alleged conduct affected Kaisamba-Kanneh. The court also rejected the argument that a future amended complaint should prevent dismissal, explaining that the court could consider only the pleadings before it and that Kaisamba-Kanneh had not amended the complaint or sought leave to amend.

Disposition

The court ordered that the defendants’ motion to dismiss was GRANTED and that the complaint was DISMISSED without prejudice. Because the dismissal was without prejudice, the order did not use the term that would bar refiling, but the opinion itself does not describe any further filing procedure beyond noting that Kaisamba-Kanneh had not amended or sought permission to amend.