Carsten James Quinlan v. Fraser, Alissa Puls

CourtCourt of Appeals of Minnesota
DecidedAugust 25, 2025
Docketa251084
StatusPublished

This text of Carsten James Quinlan v. Fraser, Alissa Puls (Carsten James Quinlan v. Fraser, Alissa Puls) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carsten James Quinlan v. Fraser, Alissa Puls, (Mich. Ct. App. 2025).

Opinion

STATE OF MINNESOTA IN COURT OF APPEALS A25-1084

Carsten James Quinlan, Appellant,

vs.

Fraser, et al., Respondents,

Alissa Puls, Respondent.

Filed August 25, 2025 Appeal dismissed Frisch, Chief Judge

Washington County District Court File No. 82-CV-24-5866

Carsten J. Quinlan, Woodbury, Minnesota (pro se appellant)

William L. Davidson, Ryan C. Ellis, Lind, Jensen, Sullivan & Peterson, Minneapolis, Minnesota (for respondents Fraser, Kallie Uner, Sara Haubrich)

Alan P. King, Natalie R. Cote, Goetz & Eckland PA, Minneapolis, Minnesota (for respondent Alissa Puls)

Considered and decided by Frisch, Chief Judge; Larkin, Judge; and Bond, Judge.

SYLLABUS

A district court abuses its discretion in certifying entry of a final partial judgment

under Minn. R. Civ. P. 54.02 when the district court fails to provide reasons for the

certification and the basis for the certification is not otherwise apparent from the record. SPECIAL TERM OPINION

FRISCH, Chief Judge

In this interlocutory appeal, appellant Carsten James Quinlan seeks review of a May

6, 2025 partial judgment dismissing certain claims against respondents Fraser, Kallie Uner,

and Sara Haubrich (the Fraser parties). We questioned whether the district court acted

within its discretion in certifying the partial judgment for immediate appeal, and if not,

whether we must dismiss this appeal as taken from a nonappealable partial judgment.

Quinlan, the Fraser parties, and respondent Alissa Puls filed informal memoranda. On July

29, 2025, we filed a special term order dismissing the appeal, with an opinion to follow. 1

We now explain that we dismiss this appeal because the district court did not provide any

reasons for its certification decision, and it is not discernable from the record that

certification of a final partial judgment is appropriate.

DECISION

In 2024, Quinlan sued Puls and the Fraser parties. 2 In the complaint, which Quinlan

filed as a self-represented party, Quinlan asserted claims of civil conspiracy and intentional

infliction of emotional distress against both Puls and the Fraser parties. Quinlan also

asserted claims of defamation, negligence, failure to report child abuse, negligent infliction

1 In our July special term order, we also determined that the district court’s partial judgment was not appealable under Minn. R. Civ. App. P. 103.03(g), concluding that the Fraser parties’ motion to dismiss did not create a special proceeding separate and apart from the merits of the parties’ claims. 2 According to the complaint, Fraser is a mental-health organization in Minnesota, and Uner and Haubrich are employees of the organization.

2 of emotional distress, vicarious liability, and ratification against the Fraser parties. Quinlan

generally alleged that Fraser therapists harmed Quinlan and Quinlan’s minor children by

supporting a “false narrative of abuse” by Quinlan. Quinlan alleged that Fraser therapists

took these actions because of “manipulation and fraud” by Puls, the children’s mother.

The Fraser parties moved to dismiss six of Quinlan’s eight claims against them—

civil conspiracy, defamation, negligence, negligent infliction of emotional distress,

vicarious liability, and ratification. 3

The district court granted the Fraser parties’ motion to dismiss. The district court

dismissed Quinlan’s defamation claim against the Fraser parties in its entirety and

dismissed Quinlan’s claims of civil conspiracy, vicarious liability, and ratification “based

on” the defamation claim. The district court also dismissed Quinlan’s claims for

negligence and negligent infliction of emotional distress “to the extent those claims are

premised on communications” the Fraser parties had “in connection with any custody battle

or the Washington County termination of parental rights matter,” as well as Quinlan’s

claims of civil conspiracy, vicarious liability, and ratification “based on” those

communications.

Although no party asked the district court to certify entry of a final partial judgment

on the dismissal order to allow an immediate appeal under Minn. R. Civ. P. 54.02, the

3 The Fraser parties sought dismissal pursuant to the Minnesota Uniform Public Expression Protection Act (UPEPA), Minn. Stat. §§ 554.07-.20 (2024), which allows a party, within 60 days after being served with a complaint or other pleading that asserts a cause of action subject to UPEPA, to bring a special motion for expedited relief to dismiss that cause of action. Minn. Stat. § 554.09.

3 district court included language consistent with rule 54.02, that “there being no just reason

for delay, let judgment be entered accordingly.” On May 6, 2025, the district court entered

judgment on the partial dismissal order. In addition to the claims against the Fraser parties

that were not dismissed, both of Quinlan’s claims against Puls remain pending in the

district court. 4

The thrust of the rules governing the appellate process is that appeals should not be

brought or considered piecemeal. Emme v. C.O.M.B., Inc., 418 N.W.2d 176, 179 (Minn.

1988). Notwithstanding this general policy, under Minn. R. Civ. App. P. 103.03(a), an

appeal may be taken from a partial judgment entered pursuant to Minn. R. Civ. P. 54.02.

When multiple claims for relief or multiple parties are involved in an action, a district court

may direct the entry of a final judgment as to one or more but fewer than all the claims or

parties “only upon an express determination that there is no just reason for delay and upon

an express direction for the entry of judgment.” Minn. R. Civ. P. 54.02; see also Minn. R.

Civ. App. P. 104.01, subd. 1 (providing that an appeal may be taken from a partial judgment

entered pursuant to Minn. R. Civ. P. 54.02 within 60 days of its entry). 5

4 In their memorandum filed in this court, the Fraser parties assert that the district court’s dismissal order did not dismiss portions of Quinlan’s negligence and negligent-infliction- of-emotional-distress claims unrelated to the communications regarding the Washington County termination-of-parental-rights matter. They also assert that “any claims for civil conspiracy, vicarious liability, or ratification related to other remaining claims were not dismissed either.” Our resolution of this matter does not require us to determine whether these claims were dismissed in whole or in part, and we express no opinion on that question. 5 We note that an interlocutory appeal of a final partial judgment is mandatory. Javinsky v. Comm’r of Admin., 725 N.W.2d 393, 397 (Minn. App. 2007). We cannot review a final partial judgment or its inherent issues after the time to appeal that judgment has expired. Id.

4 Minn. R. Civ. P. 54.02 “is intended to reduce piecemeal appeals by limiting appeals

from judgments that resolve only part of the litigation” and “to liberalize the appellate

process for parties who might be prejudiced by waiting to appeal a decision where other

claims or liabilities are yet to be decided.” T.A. Schifsky & Sons, Inc. v. Bahr Constr., LLC,

773 N.W.2d 783, 787 (Minn. 2009).

Because the May 6, 2025 judgment did not resolve all claims against all parties, it

is a partial judgment.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Javinsky v. Commissioner of Administration
725 N.W.2d 393 (Court of Appeals of Minnesota, 2007)
Emme v. C.O.M.B., Inc.
418 N.W.2d 176 (Supreme Court of Minnesota, 1988)
T.A. Schifsky & Sons, Inc. v. Bahr Construction, LLC
773 N.W.2d 783 (Supreme Court of Minnesota, 2009)
Contractors Edge, Inc. v. City of Mankato
863 N.W.2d 765 (Supreme Court of Minnesota, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Carsten James Quinlan v. Fraser, Alissa Puls, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carsten-james-quinlan-v-fraser-alissa-puls-minnctapp-2025.