Steffen v. St. Paul Eye Clinic, P.A.

Background

Eric Steffen filed an employment-discrimination action against St. Paul Eye Clinic, P.A. in state court in April 2020. His complaint asserted eight claims: four under federal law and four under state law. The clinic removed the case to federal court based on federal-question jurisdiction.

The clinic later moved for summary judgment on all claims. Summary judgment is a decision without a trial when the evidence would not allow a reasonable factfinder to rule for the opposing party. The court granted summary judgment on the seven employment-discrimination claims because, even viewing the evidence favorably to Steffen, a factfinder could not reasonably conclude that he was an employee of the clinic. The court declined to exercise supplemental jurisdiction over the remaining state-law breach-of-contract claim. It dismissed the discrimination claims with prejudice and the contract claim without prejudice.

Motion for Relief

Steffen moved under Rule 60(b)(6) of the Federal Rules of Civil Procedure for relief from that judgment. He said that, if the judgment were reopened, he would seek to amend his complaint to add discrimination theories under the Minnesota Human Rights Act. He argued that these proposed claims would not require proof that he was an employee under that law.

Rule 60(b)(6) permits relief from a judgment only in extraordinary circumstances. The court found no qualifying circumstance. Steffen was aware of the alternative theory during the original case and could have sought to amend before judgment. Instead, he waited until after the deadline in the pretrial order, completion of the summary-judgment briefing, the hearing on the motion, and the court’s summary-judgment ruling.

The court also gave an independent jurisdictional reason for denying relief. The proposed claims arose entirely under state law. The complaint did not establish another basis for the court’s original jurisdiction over those claims, and the court had already declined to exercise supplemental jurisdiction over the existing state-law contract claim. The court stated that it would likewise decline supplemental jurisdiction over the proposed claims even if Steffen had timely sought to add them.

Disposition

The court denied Steffen’s motion for relief from judgment. The order did not reopen the judgment or authorize amendment of the complaint. The court also rejected Steffen’s argument that the clinic had implicitly consented to amendment by not responding to a new theory mentioned in a footnote, explaining that the clinic had no obligation to respond to an argument unrelated to the claims in the operative complaint.