Bethune v. Baker

Background

The order addresses three cases filed by Jason Lavet Bethune: one against Scott Baker, one against Matthew Schidmt, and one against David Knutson, Matthew Schmidt, Scott Baker, Ted Knutson, Dakota County ALL, and Dakota District Court. In a January 2022 order, the court declined to exercise jurisdiction under the Younger abstention doctrine, which applies when a federal court pauses or avoids interfering with certain ongoing state proceedings. Because Bethune's federal cases sought damages, the court stayed them while two Minnesota state criminal matters were pending.

The January 2022 order required Bethune to notify the court when the state proceedings, including any appeals, were complete. The court received no such notice and independently reviewed the state-court records. In one state case, Bethune was found incompetent to proceed, and the records later stated that the charges were dismissed. In the other, he pleaded guilty to one petty-misdemeanor count, received a sentence continued for dismissal after a three-month probation period, and the records stated that the relevant charges were dismissed. Based on that review, the court concluded that the state cases were complete for practical purposes.

Ruling

The court lifted the stays in all three federal cases and directed the clerk to administratively reopen them. It also addressed an unresolved filing-fee issue: Bethune had not paid the filing fee in any of the three cases, and the court had previously dismissed his applications to proceed without paying the fee.

For each case Bethune wishes to continue, the court ordered him, within 21 days of the order's date, either to pay that case's filing fee or to apply to proceed without paying it. The court stated that it will dismiss without prejudice any case in which he does neither, for failure to prosecute under Federal Rule of Civil Procedure 41(b). The court did not dismiss the cases in this order. Judge David S. Doty signed the order.