Patrick Joseph Schiltz

Jeanette Renstrom, a former head grocery buyer at Nash Finch's St. Cloud distribution center, sued the company under the Equal Pay Act, Title VII, and the Minnesota Human Rights Act, claiming she was paid less than two male head grocery buyers at other centers for equal work. The court granted Nash Finch's motion for summary judgment. It held that the male employees were not proper comparators under the EPA because they worked at different distribution centers, which qualified as separate establishments, and because Renstrom's job involved less responsibility, such as supervising fewer buyers and managing smaller volumes. The court also noted that Renstrom did not pursue a separate disparate-treatment claim under Title VII or the MHRA.

labor & employmentcivil rights

Wendy Binion sued the City of St. Paul and multiple police officers under federal and state law after her arrest while videotaping protests at the 2008 Republican National Convention. Officers acted on a radio alert describing a woman carrying bricks and detained Binion, who matched the description and wore press credentials, but determined within minutes that she had no weapons or bricks. The court granted in part and denied in part the defendants' summary judgment motion, holding that officers could initially rely on information from other officers for qualified immunity purposes but could not disregard plainly exculpatory facts discovered on the scene when assessing ongoing detention or arrest. Factual disputes over events after the initial stop, including crowd interactions, prevented full resolution on certain claims such as excessive force or false arrest.

civil rightsfree speechcriminal lawprocedure

In Young v. Klass, plaintiff Dwight Young sued security guard Kyle Klass and his employer SecureForce after being instructed to leave a Minneapolis arcade, arrested shortly afterward by police on disorderly conduct and trespassing charges based on information from Klass, and held overnight in jail before the charges were dropped. Young asserted state-law claims against Klass for malicious prosecution, abuse of process, false imprisonment, and negligence. The court denied summary judgment on the malicious-prosecution and false-imprisonment claims, granted summary judgment on the abuse-of-process claim, and granted in part and denied in part summary judgment on the negligence claim, because genuine issues of material fact existed under the plaintiff's version of events regarding whether Klass provided false information that caused the arrest and prosecution.

criminal lawtorts & liability

In United States v. Foster, a jury convicted defendant Rodney Foster of unlawfully possessing a firearm and ammunition, but the district court later granted his motion for acquittal after finding that the gun and ammunition had been seized in violation of the Fourth Amendment. The government moved for reconsideration, arguing for the first time that Foster lacked Fourth Amendment standing to challenge the search of the car because he was only a passenger and did not own it. The court denied the motion, holding that the government had waived the standing argument by failing to raise it at any point before, during, or after trial despite multiple opportunities, and that Supreme Court precedent establishes such arguments are waivable and not jurisdictional.

criminal lawprocedure

The case involves plaintiffs Patricia Gearin and her recycling businesses suing the City of Maplewood and its building official under 42 U.S.C. § 1983, alleging First Amendment retaliation, interference with petition and court access rights, equal protection violations, and procedural and substantive due process claims arising from code enforcement actions on a commercial building purchased for business relocation. These actions followed Gearin's prior complaints about toxic dumping near her home and the City's permitting decisions. The court addressed defendants' motion for summary judgment, granting it in part and denying it in part after reviewing the factual background of occupancy classifications, zoning requirements, inspections, and the parties' disputes over compliance.

free speechcivil rightspropertybusiness & regulatory

In United States v. Foster, defendant Rodney Foster was charged under federal law with unlawful possession of a firearm and ammunition by a felon after Minneapolis police stopped the car in which he was a passenger, searched his person and the vehicle, and recovered a magazine of ammunition and a loaded handgun. Following a jury conviction, the court reconsidered its earlier denial of Foster's motion to suppress and concluded that the traffic stop and searches violated the Fourth Amendment, as the officers lacked probable cause for the stop and reasonable suspicion for the searches of Foster and the car. The court therefore suppressed the gun and ammunition, determined that insufficient evidence remained to support the conviction, and granted Foster's motion for judgment of acquittal notwithstanding the verdict.

criminal lawgunscivil rightsprocedure

In this tax refund case, Wells Fargo sued the United States for a refund of taxes and interest, and the government responded with an offset or recoupment defense based on Wells Fargo's alleged negligence in reporting a 2003 transaction on its tax return. Wells Fargo moved to strike the defense under Rule 12(f), but a magistrate judge denied the motion, and the district court affirmed that ruling. The court held that the magistrate's decision was neither clearly erroneous nor contrary to law, as the cited precedents addressed burdens of proof rather than pleading standards and were distinguishable on their facts. It further concluded that the plausibility requirements from Iqbal and Twombly do not apply to affirmative defenses under Rules 8(b) and 8(c), given differences in the rules' text, the parties' respective positions, and the practical effects on litigation. Even assuming those standards applied, the court found the government's defense adequately pleaded under Form 11.

taxesprocedure

This case involves plaintiff Samuel Edeh suing defendant Midland Credit Management for alleged violations of consumer protection laws during debt collection efforts on a credit card debt that Edeh disputed. Edeh claimed Midland reported the debt to credit agencies before verifying it, made unauthorized calls, and committed other violations under the FDCPA, Rosenthal Act, Minnesota Collection Agencies Act, TCPA, and FCRA. The court adopted most of the magistrate judge's report and recommendation, granting summary judgment to Edeh on liability under the FDCPA (for reporting the debt without prior verification) and TCPA, dismissing the Rosenthal Act and Minnesota claims, denying summary judgment on the FCRA claim, and reserving damages issues for trial. On the discovery appeal, the court affirmed in part and vacated in part the magistrate's order compelling production, limiting it based on relevance to the remaining claims. The core reasoning centered on statutory interpretations requiring debt verification before collection activities and the scope of permissible discovery tied to the surviving claims.

business & regulatoryprocedure

In Lawrence v. City of St. Paul, plaintiff Kimberly Lawrence sued her former boyfriend, a Minneapolis police officer, and several St. Paul law-enforcement officers under 42 U.S.C. § 1983 and the Minnesota Constitution, alleging violations of her rights arising from a 2003 late-night confrontation at the boyfriend's home that led to her arrest and guilty plea on criminal charges while he faced none. Six years later, she claimed the officers acted with bias, used excessive force, failed to investigate properly, and retaliated against her by towing her vehicle. The court granted the defendants' motions to dismiss or for summary judgment on all claims except one, holding that there is no private right of action under the Minnesota Constitution, that the boyfriend was not acting under color of state law during the altercation, and that the evidence did not support the remaining constitutional or conspiracy allegations. The surviving claim is a First Amendment retaliation claim against the St. Paul officers concerning the towing of Lawrence's car, which the court found could proceed because factual disputes existed about whether her protected speech motivated that action.

civil rightsfree speechcriminal lawprocedure

This case involves Hartford Fire Insurance Company, as subrogee of Buffets, Inc., seeking to recover nearly $3 million paid out under an employee-theft insurance policy after Buffets employees Donald Clark and Robin Parsons (of Carr Freight) engaged in a kickback scheme involving overbilling for shipping services; Carr Freight was affiliated with defendant Transgroup Express, Inc., which handled billing for interstate shipments. Hartford asserted claims against Transgroup including intentional and negligent misrepresentation, conversion, unjust enrichment, aiding and abetting breach of fiduciary duty, and civil conspiracy, primarily on vicarious liability theories but also direct liability. On cross-motions for summary judgment, the court denied Hartford's motion in full and granted Transgroup's motion in part by dismissing the direct-liability portions of five counts, while denying the motion as to the remaining claims. The court applied the summary judgment standard under Fed. R. Civ. P. 56, finding no basis for direct liability but genuine issues of material fact precluding judgment on vicarious liability, and addressed evidentiary matters such as the admissibility of a post-incident report under Fed. R. Evid. 407.

criminal lawbusiness & regulatoryproceduretorts & liability

Joan Najbar sued the United States after the Postal Service returned a letter she sent to her son serving in Iraq stamped "DECEASED," even though he was alive, leading to emotional distress and related physical and financial harms. She asserted state-law tort claims for intentional infliction of emotional distress, negligence, negligent infliction of emotional distress, and negligence per se under the Federal Tort Claims Act. The court granted the government's motion to dismiss for lack of subject-matter jurisdiction. It held that the claims fell within the FTCA's exception barring suits for misrepresentation under 28 U.S.C. § 2680(h), as the suit centered on the communication of false information about her son's status.

torts & liabilityprocedurefederal power

This case involves a product-liability lawsuit brought by North Carolina plaintiffs against Delaware and California defendants over injuries allegedly caused by a pain pump implanted during shoulder surgery in North Carolina in 2001. The plaintiffs filed the action in the District of Minnesota, which has no connection to the parties, events, or injuries. The court transferred the case to the Eastern District of North Carolina under 28 U.S.C. § 1404(a), finding that the convenience of the parties and witnesses overwhelmingly favored transfer and that the plaintiffs' choice of forum deserved minimal deference because it was selected to take advantage of Minnesota's longer statutes of limitations rather than any connection to the dispute.

proceduretorts & liability

In this case, the Der family sued Isanti County, its sheriff, and a deputy sheriff under 42 U.S.C. § 1983, alleging that the deputy's warrantless entry into their home for a child welfare check violated the Fourth and Fourteenth Amendments, along with various state-law tort claims such as assault and false imprisonment. The court granted the defendants' motion for summary judgment on all Fourteenth Amendment claims and on the Fourth Amendment claims against the county and sheriff, but denied summary judgment on the Fourth Amendment claim against the deputy and on the state-law claims. The core reasoning was that the plaintiffs failed to show deliberate indifference by the county or sheriff regarding training or supervision, that substantive due process claims could not proceed separately from the specific Fourth Amendment claim, and that material factual disputes existed regarding whether the deputy forced entry without consent or exigent circumstances.

civil rightsproceduretorts & liability

This case involves former Muslim employees of Celestica and Adecco who alleged religious discrimination and failure to accommodate their duty to pray five times daily under Title VII and the Minnesota Human Rights Act. The court denied defendants' motion for summary judgment on the reasonable-accommodation claims. Disputes of material fact existed on whether plaintiffs notified defendants of the conflict, whether they suffered adverse actions, and whether the offered transfer to the first shift was a reasonable accommodation. The court reasoned that reasonableness is assessed based on the totality of circumstances, including whether the accommodation fully resolved the conflict given varying beliefs and any work-related costs to employees.

labor & employmentcivil rightsreligious liberty

The case involved a homeowner who refinanced his mortgage and later sought to rescind the loan under the Truth in Lending Act due to allegedly inadequate disclosures at closing, while also requesting information under the Real Estate Settlement Procedures Act; after partial responses and the start of foreclosure, he sued the lenders for violations of TILA, RESPA, and state deceptive trade practices law. The court denied the plaintiff's motion to remand the case to state court and granted in part the defendants' motions to dismiss, dismissing the TILA claim regarding failure to rescind and inadequate disclosures with prejudice, the state law claim with prejudice, but allowing one aspect of the TILA claim regarding an improper $12,000 payment to proceed, and denying dismissal of the RESPA claim without prejudice. The core reasoning centered on the timeliness of claims, the sufficiency of responses to information requests, and the failure to state viable claims under certain statutes.

business & regulatorypropertyprocedure

This case involved a dispute between auto-glass repair shop Alpine Glass and insurers Illinois Farmers Insurance and Mid-Century Insurance over payment for windshield repairs billed to the insurers' policyholders. Alpine sought to consolidate and arbitrate 1,120 "short-pay" claims under Minnesota's No-Fault Automobile Insurance Act, after the insurers paid less than the billed amounts; the insurers counterclaimed for a declaration of non-liability. After dismissing most counterclaims and ordering consolidated arbitration, an arbitrator awarded Alpine over $400,000, and the court denied the insurers' motion to vacate the award. The core reasoning was that valid policy assignments from insureds to Alpine allowed the claims to proceed to arbitration, Minnesota law required payment of competitive fair prices but did not support vacating the arbitrator's determination on the facts presented, and procedural objections like postponement lacked merit.

business & regulatoryprocedure

Kardia moved for a preliminary injunction to prevent Freeland from foreclosing on and selling assets in which Freeland claimed a security interest under an Asset Purchase Agreement for a $10 million transaction, alleging that fraud rendered the agreement and security interest invalid. The court granted the injunction only for assets that came into existence after May 8, 2008, finding those items were not covered by the collateral description in the agreement and bill of sale, but denied the motion for all other assets because Kardia did not meet its burden to show the security interest was invalid or that the items fell outside the collateral. Applying the Dataphase factors, the court concluded Kardia showed a likelihood of success on the merits only as to the post-May 2008 assets and declined to require a bond.

business & regulatorypropertyprocedure

The case involves plaintiff Stephanie Chappell, a former junior-high and high-school teacher, who sued her employer Butterfield-Odin School District No. 836 for discrimination, retaliation, and failure to accommodate under the Americans with Disabilities Act, the Rehabilitation Act, and the Minnesota Human Rights Act, based on her epilepsy and neck condition. The dispute arose after Chappell requested schedule changes, equipment, and other adjustments to reduce seizure risks and neck strain during her short employment in fall 2005, following which the district ended her employment. On the district's motion for summary judgment, the court granted the motion as to all claims under the MHRA and the failure-to-accommodate claims under the ADA and Rehabilitation Act, but denied the motion on the remaining discrimination and retaliation claims. The court treated the ADA and Rehabilitation Act claims similarly due to overlapping standards and found that some claims lacked sufficient evidence of disability or timely accommodation requests, while others presented triable issues of fact.

labor & employmentcivil rights

The case involved claims by Arizant Holdings Inc. and related companies against former employee Gregory Gust for breach of contract, including noncompete and confidentiality agreements, and misappropriation of trade secrets, based on Gust's post-employment work as a consultant for a competitor selling a competing patient-warming system and his forwarding of company emails. The court granted Gust's motion for summary judgment and denied Arizant's cross-motion. The core reasoning was that Arizant failed to demonstrate it had suffered or was likely to suffer any harm from Gust's actions, which was required to support the requested relief such as an injunction; the court also noted related issues with the enforceability and scope of the agreements but did not reach them due to the lack of harm.

labor & employmentbusiness & regulatoryprocedure

This case is a patent infringement suit by the Regents of the University of Minnesota against AGA Medical Corp. over U.S. Patents No. 6,077,281 and 6,077,291, which cover devices for closing heart septal defects. The court held a Markman hearing to construe disputed claim terms after the parties submitted an amended joint claim-construction statement and briefs. The court decided the meanings of terms including "occluding" and "membrane" by applying the ordinary meaning to a person of skill in the art, primarily using the shared patent specification and prosecution history (including terminal disclaimers) as intrinsic evidence, supplemented by dictionaries where needed. The core reasoning is that claim construction is a legal question for the court, must be consistent across related patents in the family, and treats the specification read in light of the prosecution history as the key interpretive source.

propertyprocedure