UPDATE: Plaintiff Files Oppositions to All Motions to Dismiss
Date: September 3, 2025
Event: On September 3, 2025, Plaintiff filed timely and complete oppositions to all three pending Motions to Dismiss in Strickland v. Ramsey County, et al. These included:
- State Defendants: Opposition addressing referees Clysdale, Larmouth, Rossow, Elsmore, and court administrator Nicole Rueger.
- County Defendants: Opposition contesting Ramsey County's municipal immunity arguments and challenging the County's attempt to distance itself from systemic court failures documented in the federal record.
- Barna, Guzy & Steffen (BGS): Opposition filed despite BGS's failure to submit a required memorandum in support of its Motion to Dismiss. BGS did not file its memorandum until September 4, one day late, leaving Plaintiff no meaningful opportunity to respond to arguments that did not yet exist.
Context and Concerns
Filing three oppositions in a single day-each addressing distinct legal theories and defendants-required Plaintiff to adhere closely to procedural deadlines even while navigating the aftereffects of irregular service, altered court records, and inconsistent docket management.
BGS's late memorandum is part of a broader pattern: private counsel aligned with Ramsey County repeatedly missing deadlines, submitting incomplete filings, and relying on the court's tolerance for defective work. Plaintiff's compliance with every deadline stands in stark contrast.
Appearance of Procedural Imbalance
The staggered filings created an inherent structural disadvantage. While the State and County defendants filed full memoranda, Plaintiff was forced to respond to BGS's bare-bones motion without the benefit of knowing what arguments the firm would eventually assert.
When BGS filed its missing memorandum the next day, it did so after Plaintiff's opposition had already been submitted-meaning the firm's substantive arguments were insulated from a contemporaneous rebuttal. This dynamic mirrors the wider procedural imbalance that has defined the state-court record.
Despite these obstacles, Plaintiff's filings on September 3 ensure a complete and timely opposition record for judicial review.