Kuether v. Posley

CourtDistrict Court, E.D. Wisconsin
DecidedFebruary 13, 2025
Docket2:23-cv-00948
StatusUnknown

This text of Kuether v. Posley (Kuether v. Posley) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kuether v. Posley, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

DEBORAH KUETHER,

Plaintiff,

v. Case No. 23-CV-948

KEITH POSLEY, et al.,

Defendants.

DECISION AND ORDER

1. Background Deborah Kuether, the former Director of Literacy for Milwaukee Public Schools (MPS), alleges she was subjected to significant and pervasive discrimination and retaliation by multiple high-level MPS officials because she is a white woman and spoke out about officials promoting unqualified or less-qualified persons based on their race. This led to officials sabotaging her work, punitively reassigning her, and eventually constructively discharging her. The allegations that give rise to this action were recounted more thoroughly in the Court’s decision on the defendants’ motion to dismiss Kuether’s first amended complaint. Kuether v. Posley, No. 23-CV-948, 2024 WL 218421 (E.D. Wis. Jan. 19, 2024). Following that decision, Kuether filed a second amended complaint (ECF No. 37), which the defendants moved to dismiss in part (ECF No. 40). The Court partially

granted that motion. Kuether v. Posley, No. 23-CV-948, 2024 WL 3026518 (E.D. Wis. June 17, 2024). On November 27, 2024, the parties filed a Joint Motion for Protective Order (ECF

No. 60), which this Court granted on December 2 (ECF No. 62). The defendants have since filed several motions related to discovery disputes: Motion for Protective Order (ECF No. 63), Motion to Amend Case Caption (ECF No. 66), and Motion for Sanctions

under Rule 11 (ECF No. 72). The motions are fully briefed and ready for resolution. (ECF Nos. 76, 79, 80, 82.) 2. Analysis 2.1. Mann as a Defendant

The parties dispute whether Jacqueline Mann is still a defendant in this case. The defendants contend that Kuether’s Second Amended Complaint brought one claim against Mann—for a violation of Wisconsin’s Public Records Law—which this Court

dismissed, thus terminating Mann as a party. (ECF No. 64 at 9.) Kuether’s counsel expressed to the defendants’ attorney that Mann was still a defendant because she still appears in the caption on PACER. (ECF No. 81-3 at 11 (“To make sure we are operating in the same universe can you confirm that when you search

this case in PACER, Dr. Mann is listed as a party represented by Von Briesen.”).) This led to the defendants filing their motion to amend the case caption to remove Mann from the case caption. (ECF No. 66.)

Kuether now contends that Mann is still a defendant in this case because Mann is included in her “§ 1983/First Amendment violation claims” because, despite her “oversight” in failing to mention Mann among the defendants in those claims, her

“factual averments give Defendants sufficient notice of her intent to pursue a Section 1983 claim against Mann.” (ECF No. 76 at 3, 6.) While Kuether is unclear about whether she intended to include Mann as a defendant in one or both of her First Amendment

§ 1983 claims, the Court will assume she meant to include Mann in both claims. Kuether’s Second Amended Complaint includes headings for each Count, identifying which defendants are sued for which claims. (ECF No. 37 at 27-34.) Mann only appears under the Wisconsin Public Records Law claim, which this Court

dismissed. Kuether, 2024 WL 3026518, at *8. Mann is not listed as one of the defendants under either of Kuether’s First Amendment claims, nor do the allegations in support of those claims include any

reference to Mann. In her previous briefing before this Court on whether her First Amended Complaint stated a claim against individual Board member defendants for violation of her First Amendment rights, Kuether detailed the facts she believed made each

defendant personally liable; she never mentioned Mann. (ECF No. 26 at 12-20 (discussing Posley, Fermin, Cotton, Holiday, Peterson, O’Halloran, Gokalgandhi, Carr, and Herndon, but not Mann)); Kuether, 2024 WL 218421, at *12 (dismissing “all claims

against [the Board members] individually … with the exception of Kuether’s First Amendment claim against O’Halloran”). In fact, it appears Kuether never even commenced service against Mann. Fed. R. Civ. P. 4(c)-(d). Rather, Mann only appears in

Kuether’s Second Amended Complaint, where Kuether incorporated factual allegations against Mann in the background facts and listed her as a defendant only under the Public Records claim.

While the Second Amended Complaint includes a handful of factual allegations relating to Mann’s and Kuether’s speech in some of the over 130 paragraphs and 26 pages preceding her claims, none of these facts appear in the short plain statement of Kuether’s First Amendment claims. Fed. R. Civ. P. 8 (requiring the pleading to include

“a short and plain statement of the claim showing that the pleader is entitled to relief”). Her shotgun pleading that “Plaintiff realleges and incorporates by reference all previous allegations” (ECF No. 37, ¶¶ 136, 147) did not put the defendants on notice

that Kuether intended to include Mann as a defendant in the two First Amendment claims even though Mann was not named as a defendant in those claims. U.S. ex rel. Garst v. Lockheed-Martin Crop., 328 F.3d 374, 378 (7th Cir. 2003) (“Rule 8(a) requires parties to make their pleadings straightforward, so that judges and adverse parties need

not try to fish a gold coin from a bucket of mud. … [T]he substantial subsidy of litigation … should be targeted on those litigants who take the preliminary steps to assemble a comprehensible claim.”).

Mann is no longer a defendant in this lawsuit. The defendants’ motion to Amend the Case Caption to reflect such will be granted. The defendants also seek Rule 11 sanctions for Kuether’s insistence on serving

discovery on someone who is no longer a party to the lawsuit. (ECF No. 72.) But Rule 11 sanctions do not apply to discovery requests. Fed. R. Civ. P. 11(d). Thus, the defendants’ motion for Rule 11 sanctions will be denied.

2.2. Motion for Protective Order The defendants’ motion for a protective order concerns the scope and manner of upcoming depositions. Many of the defendants’ concerns stem from their history with Kuether, Kuether’s counsel (Attorney Ben Hitchcock Cross), and their YouTube channel.

Kuether and Attorney Hitchcock Cross run a YouTube channel, titled “Deliberate Indifference Wisconsin,” primarily dedicated to discussing this and other cases with which they are involved. See Deliberate Indifference Wisconsin (“DIWI”)

(@deliberateindifferencewi), YouTube, https://www.youtube.com/@deliberateindifferencewi (last accessed Feb. 13, 2025). At this time, the YouTube channel has over 7,300 subscribers, 800 videos, and nearly 1.5 million views. The YouTube videos include depositions that Attorney Hitchcock Cross took in a prior, related matter. Kuether v. Milwaukee Pub. Schs., Wis. Dep’t of Workforce Dev.,

Equal Rts. Div., Case No. CR202100861. Some of these deposition videos come not from the videographer’s camera but from a secondary camera (apparently unbeknownst by defense counsel), capturing the videographer’s camera, the witness, opposing counsel,

and off-the-record conversations.1 The video thumbnails include unflattering photos of the witnesses and opposing counsel, and many of the video titles are, as defendants put it, “inflammatory.” (ECF No. 64 at 4.) Many of the defendants’ concerns relate to

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