UPDATE: Motion for Reimbursement of Wrongfully Extracted Fees
Date: November 14, 2025
On November 14, 2025, Plaintiff filed a Motion for Reimbursement of Wrongfully Extracted Fees and Request for Prospective Relief in Strickland v. Ramsey County, et al.. The motion asks the federal court to order Ramsey County to return more than $2,000 in fees that were imposed despite an existing hardship-based fee waiver and to bar further fee manipulation going forward.
Summary in Context
The reimbursement motion does not arise from a single bad charge; it documents a pattern. After Plaintiff was granted in forma pauperis status in the underlying HRO matter, Ramsey County continued to treat her as a paying litigant, layering new fees onto the same dispute in defiance of Minn. Stat. § 563.01.
The pattern intensified in November 2025. Judge Nicole Starr denied Plaintiff's request to extend the existing fee waiver based solely on household income-ignoring sworn statements that Plaintiff, a disabled SSI recipient, does not control those funds. Three days later, Attorney Kyle T. Manderfeld filed a jurisdictionally void “Motion for Contempt” in district court at 4:07 p.m. on November 10, the night before Veterans Day, while the waiver issue was still in flux.
To protect her appellate rights, Plaintiff was forced to pay a $550 fee that same afternoon to perfect the appeal, notify the Court of the contempt filing, and ensure jurisdiction was fully vested in the Minnesota Court of Appeals.
What the Motion Seeks
The reimbursement motion asks Judge Frank to order Ramsey County to return specific fees tied to the same underlying HRO dispute, including:
- $550 paid on November 10, 2025 to respond to a jurisdictionally void contempt motion and perfect the appeal;
- $550 previously paid for a writ of mandamus arising from the same matter;
- $550 submitted by money order and retained for months without adjudication, forcing recovery efforts;
- $85 to file a Conciliation Court harassment claim that was dismissed with prejudice without adjudication;
- $325 to remove that same case to district court to preserve the claims;
- $100 to file a Motion for Default Judgment that has languished without ruling; and
- ancillary costs associated with recovering the retained money order.
Plaintiff also asks for a declaration that the original fee waiver applied to all related proceedings and an injunction forbidding Ramsey County from imposing any further fees in the same dispute without clear statutory authority and compliance with ADA Title II.
Fee Manipulation as a Pattern
The motion traces a broader pattern of financial obstruction. In the civil case 62-CV-25-6817, Plaintiff paid $85 to file in Conciliation Court and $325 to remove the matter to district court. After removal, the court accepted an unexplained $425 payment from Defendant and then closed Plaintiff's case administratively. No Minnesota statute authorizes a defendant to pay such a fee or allows a court to terminate a plaintiff's case on that basis.
When Plaintiff attempted to file a Motion to Vacate the sua sponte dismissal, Civil Division Administrator Michael Upton insisted that she pay an additional $100 motion fee-even though the dismissal had been initiated by the court itself. One week later, on the same day the OLPR opened a preliminary investigation into Attorney Manderfeld, the court accepted the identical filing without requiring that $100 fee.
The motion frames these swings not as isolated mistakes but as proof that fee demands were being used as a tool to control forum access and delay or block review when it favored the County and its agents.
ADA, Due Process, and Retaliation
Plaintiff's declaration explains that she is a disabled SSI recipient with PTSD and autism-related communication impairments, and that she does not have discretionary access to her spouse's income. The motion argues that relying solely on combined household income to deny a fee-waiver extension-while ignoring sworn testimony about actual access to funds-violates both Minn. Stat. § 563.01 and the Due Process Clause.
The motion further contends that the timing of the November 10 contempt filing, combined with the County's refusal to honor the existing waiver, amounts to ADA Title II discrimination and retaliation: fees were escalated immediately after Plaintiff raised concerns about document tampering, jurisdictional defects, and prior ADA failures.
Requested Relief and What Comes Next
In addition to reimbursement of all wrongfully extracted fees, Plaintiff asks the federal court to:
- Declare that her original in forma pauperis determination applied to all filings and proceedings arising from the same HRO matter;
- Enjoin Ramsey County from imposing any further fees or payment conditions in the dispute absent express statutory authority and prior Court approval; and
- Order any additional relief needed to prevent future fee-based obstruction.
If granted, the motion would not only restore funds already extracted; it would also put a federal lock on the County's ability to use financial pressure as a gatekeeping tool against a disabled pro se litigant. As with prior filings, the motion functions as both a request for relief now and a detailed receipt for appellate and oversight bodies reviewing what happened in Ramsey County.