Lenear v. State of Minnesota, The
- Patrick Schiltz
- 0:23-cv-01477
- U.S. District Court · District of Minnesota
- 4
In Lenear v. Minnesota, Judge Schiltz dismissed the duplicative action without prejudice and denied Lenear’s other motions as moot.
Eddie Lenear’s federal action and his pending motion and fee-waiver application were affected. The named defendants were not required to litigate the merits in this action because the complaint was dismissed as duplicative.
What happened
In Lenear v. Minnesota, Eddie Lenear challenged issues related to his ongoing state criminal prosecution. He filed this federal case after filing a similar case in the same court, and he represented himself.
The court found that the two federal cases were substantially the same, sharing many defendants and nearly identical legal arguments. Because Lenear had not paid the filing fee and had asked to proceed without paying it, the court applied a federal law allowing dismissal of duplicative cases.
Judge Patrick J. Schiltz dismissed the complaint without prejudice as duplicative. He denied Lenear’s motion to dismiss and application to proceed without paying fees as moot, meaning the court considered them no longer necessary to decide.
The detailed version
- Lenear v. State of Minnesota, The · No. 0:23-cv-01477
- Patrick Schiltz
- May 26, 2023
Background
Eddie Lenear, representing himself, filed this action against the State of Minnesota, McLeod County, “Officer Grack,” Jessica J.W. Maher, Zachary Lyngaas, Ryan Hantch, and Lauren Johnson. The opinion states that Lenear was facing a state prosecution involving possession of a firearm after a crime-of-violence conviction and driving with a revoked license.
Before filing this case, Lenear had filed another federal lawsuit concerning his state prosecution. He then filed six more lawsuits on May 19, 2023, including this one. The court found that this action and the earlier federal action were “substantive clones”: they shared many defendants, and Lenear described his legal theories in nearly identical terms.
Court’s Analysis
Lenear did not pay the filing fee. Instead, he filed an application to proceed without prepaying fees or costs. That triggered review under 28 U.S.C. § 1915(e), a federal statute governing such cases.
The court relied on Eighth Circuit precedent holding that a district court may dismiss a duplicative complaint raising issues directly related to those in another pending action brought by the same party. Applying that rule, the court dismissed this action as duplicative under § 1915(e). The opinion did not decide whether Lenear’s challenges to his state prosecution were legally valid.
The court also discussed Lenear’s filing of six duplicative lawsuits on the same day. It warned that, if he continued this conduct, a court in the District of Minnesota would likely restrict him from filing new litigation in that district while unrepresented unless he first obtained permission from a judicial officer. The court did not impose that restriction in this order.
Disposition
Judge Patrick J. Schiltz ordered that Lenear’s complaint be dismissed without prejudice under 28 U.S.C. § 1915(e) as duplicative. “Without prejudice” means the order did not state that refiling was permanently barred, although the opinion does not specify what future filing would be permitted.
The court denied as moot Lenear’s “Motion to Dismiss (Rule to Show Cause)” and his application to proceed without prepaying fees or costs. The court directed that judgment be entered.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.