UPDATE: Minnesota Attorney General Moves to Dismiss State Defendants
Date: August 28, 2025
Event: On August 28, 2025, Assistant Attorney General Matt Mason filed a Motion to Dismiss on behalf of the state defendants in Strickland v. Ramsey County, et al. The motion seeks dismissal of all claims against Referees Clysdale, Larmouth, Rossow, Elsmore, and Court Administrator Nicole Rueger in their official capacities.
Mason's filing is the State's first substantive response in the federal case and presents a tightly framed set of immunity and jurisdictional arguments while expressly disavowing any position on the merits of Plaintiff's underlying allegations.
Summary of the Motion
The motion argues that Plaintiff's claims against the state defendants should be dismissed on several independent grounds, including:
- Eleventh Amendment immunity for claims against state officials in their official capacities;
- Judicial and quasi-judicial immunity for actions taken by referees and court administration in the course of adjudicating cases;
- Failure to state a claim under Rule 12(b)(6), asserting that Plaintiff has not plausibly alleged a violation attributable to the state defendants;
- Abstention and preclusion doctrines, arguing that federal review would improperly interfere with ongoing or concluded state proceedings.
The memorandum emphasizes that the Attorney General's Office appears solely to defend the institutional interests of the state judiciary and court administration, not to endorse or validate the specific conduct alleged.
Key Doctrines Invoked
Mason's motion relies on classic defensive doctrines commonly raised in civil rights litigation involving state courts:
- Eleventh Amendment & sovereign immunity: The State of Minnesota and its officials are generally immune from damages claims in federal court absent consent or a valid Ex parte Young-style claim.
- Judicial immunity: Referees' decisions on motions, orders, and case management are characterized as core judicial functions, shielded from suit even if alleged to be erroneous.
- Rooker-Feldman/abstention themes: The motion suggests that Plaintiff is effectively asking the federal court to review and reverse state-court decisions, which is framed as beyond the district court's jurisdiction.
- Pleading standards: Mason argues that the complaint's narrative of altered records and ADA retaliation is not sufficiently tied, count by count, to specific state defendant actions that would overcome immunity.
Context and Tone
In contrast to other defense filings, Mason's motion is notable for its professional, rule-bound tone. It does not attack Plaintiff personally, does not deny the existence of irregular orders or docket anomalies, and does not attempt to re-argue the state record. Instead, it focuses narrowly on:
- who may be sued in federal court,
- in what capacity,
- and under what circumstances discovery may proceed against judicial officers.
The filing positions the Attorney General's Office as a defender of structural immunity rather than a fact-based participant in the events alleged.
What This Means Going Forward
If granted in full, Mason's motion would remove the referees and court administrator from the case, leaving:
- Ramsey County and its agents,
- Barna, Guzy & Steffen and attorney Kyle Manderfeld,
- and other non-state actors
as the remaining defendants in the federal action.
Regardless of outcome, the motion forces the court to confront a central question in Plaintiff’s lawsuit: whether systemic irregularities in the state-court process may be examined through federal civil rights litigation when the primary actors are embedded within the state judiciary itself.
Plaintiff's opposition to Mason's motion will address these doctrines directly, arguing that immunity cannot be used as a blanket shield for patterns of ADA retaliation, altered records, and deliberate obstruction of access to the courts.