Carlson v. Minnesota Department of Employment and Economic Development et al
ORDER re remand. (Written Opinion) Signed by Judge Joan N. Ericksen on November 14, 2014. (CBC)
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Stephen Wayne Carlson,
Civil No. 12-644 (JNE/JJK)
Minnesota Department of Employment and
Economic Development; Commissioner
Katie Clark Sieben, 1 in Official Capacity;
and Minnesota Governor Mark Dayton, in
In December 2012, the Court adopted a Report and Recommendation, granted
Defendants’ motion for judgment on the pleadings, denied Plaintiff’s motion for a
temporary restraining order, and dismissed the case. Plaintiff appealed, and the United
States Court of Appeals for the Eighth Circuit affirmed. Plaintiff petitioned for a writ of
certiorari. The United States Supreme Court granted the petition, vacated the judgment
of the court of appeals, and remanded the case to the court of appeals for further
consideration in light of Sprint Communications, Inc. v. Jacobs, 134 S. Ct. 584 (2013).
In turn, the Eighth Circuit vacated this Court’s judgment and remanded the case for
further consideration in light of Sprint Communications.
The Court granted the parties an opportunity to submit memoranda of law.
Plaintiff did not submit one; Defendants did. Defendants asserted that the “rationale for
applying Younger abstention to [Plaintiff’s] claims for injunctive relief was undermined
Katie Clark Sieben is substituted as a defendant. See Fed. R. Civ. P. 25(d).
by . . . Sprint Communications,” that the Court’s “independent conclusion that
[Plaintiff’s] claims should be dismissed based on the doctrine of res judicata is unaffected
because the doctrine has no logical connection to abstention or the issues decided in
Sprint Communications,” and that the “dismissal of [Plaintiff’s] damages claims pursuant
to the Eleventh Amendment is also unaffected by Sprint Communications.”
Younger abstention applies in exceptional circumstances in three types of
proceedings: “First, Younger precluded federal intrusion into ongoing state criminal
prosecutions. Second, certain ‘civil enforcement proceedings’ warranted abstention.
Finally, federal courts refrained from interfering with pending ‘civil proceedings
involving certain orders . . . uniquely in furtherance of the state courts’ ability to perform
their judicial functions.’” Sprint Commc’ns, 134 S. Ct. at 591 (alteration in original)
(citations omitted). On remand, Defendants did not assert Younger abstention. It does
not apply. Nevertheless, for the reasons set forth in the Report and Recommendation,
Plaintiff’s claims are subject to dismissal based on res judicata and the Eleventh
Amendment. The Court dismisses the action with prejudice.
Based on the files, records, and proceedings herein, and for the reasons stated
above, IT IS ORDERED THAT:
This action is DISMISSED WITH PREJUDICE.
LET JUDGMENT BE ENTERED ACCORDINGLY.
Dated: November 14, 2014
s/Joan N. Ericksen
JOAN N. ERICKSEN
United States District Judge
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