McGuiness v. Jennings

CourtDistrict Court, D. Delaware
DecidedFebruary 6, 2025
Docket1:23-cv-00894
StatusUnknown

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

Bluebook
McGuiness v. Jennings, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE KATHLEEN KRAMEDAS MCGUINESS, ) CHRISTIE R. GROSS, and MY ) CAMPAIGN GROUP, LLC, ) ) Plaintiffs, ) ) v. ) C.A. No. 23-894-MN ) KATHLEEN JENNINGS, MARK ) DENNEY, ALEXANDER MACKLER, and ) FRANK ROBINSON, ) ) Defendants. )

MEMORANDUM OPINION Ronald G. Poliquin, THE POLIQUIN FIRM, LLC, Wilmington, DE – attorney for Plaintiffs

Nicholas D. Picollelli, Jr., Deputy Attorney General, Kenneth L. Wan, Deputy Attorney General, DELAWARE DEPARTMENT OF JUSTICE, Wilmington, DE – attorneys for Defendants

February 6, 2025 Wilmington, Delaware REIKA, U.S. DISTRICT JUDGE: Presently before the Court is Defendants’ partial motion to dismiss (D.I. 13) the Second Amended Complaint (D.I. 5) for failure to state a claim upon which relief may be granted, pursuant to Federal Rule of Civil Procedure 12(b)(6).! Specifically, Defendants Kathleen Jennings (“Jennings”), Mark Denney (“Denney”), Alexander Mackler (“Mackler’) and Frank Robinson (“Robinson”) (collectively, “Defendants”) assert that Plaintiffs Kathleen Kramedas McGuiness (“McGuiness”), Christie R. Gross (“Gross”) and My Campaign Group, LLC (“MYCG”) (collectively, “Plaintiffs”) fail to state a claim for relief under 42 U.S.C. § 1983 and under Delaware tort law. For the reasons set forth below, the Court GRANTS Defendants’ partial motion to dismiss. I. BACKGROUND Plaintiffs’ allegations, accepted as true at this stage of the proceedings, are as follows. McGuiness served as the Delaware State Auditor from January 2019 until October 2022. (D.I. 5 § 9). While serving in that position, McGuiness entered into contracts with Plaintiff MYCG, which is owned by Plaintiff Gross, for the provision of communication services and public policy work. (Ud. § 10). The Delaware Department of Justice opened an investigation into McGuiuness for official misconduct, arising in part from her contracts with MYCG and Gross. The investigation involved various Delaware Department of Justice employees, including Delaware Attorney General Jennings, Deputy Attorney General Denney, Chief Deputy Attorney General Mackler and Chief Special Investigator Robinson.

Initially, Defendants moved to dismiss the Second Amended Complaint in its entirety. (See D.I. 13). Defendants, however, in their reply brief, withdrew a basis for dismissal. (D.I 19 at 6). As a result, Defendants’ motion to dismiss (D.I. 13) is properly viewed as a partial motion to dismiss. (See a/so D.I. 19 at 14 (requesting dismissal “in part”)).

On September 28, 2021, the Delaware Department of Justice sought, obtained and executed a search warrant (“the Search Warrant”) at McGuiness’s office. (Id. ¶ 16). Among other items, the Search Warrant authorized the search and seizure of “[a]ll invoice and payment records for My Campaign Group and Innovate Consulting” as well as “[t]he office video system to cover

June 15, 2021 to July 1, 2021.” (D.I. 5, Ex. A at 2). In support of the Search Warrant, Defendant Robinson submitted a probable cause affidavit (“the Probable Cause Affidavit”). The Probable Cause Affidavit, in paragraphs 23 and 24, alleged that McGuiness intentionally split invoices under the MYCG contract into multiple payments to avoid official oversight and approval. (Id. ¶¶ 18- 19; see also D.I. 14 at 8). Additionally, paragraph 37 of the Probable Cause Affidavit alleged that an employee in the Auditor’s officer “called the police to report an item stolen from within the office.” (D.I. 5, Ex. A ¶ 37). On October 11, 2021, a grand jury returned an indictment of McGuiness on five criminal charges relating to her conduct as State Auditor (“the Indictment”).2 That same day, the Delaware Department of Justice held a press conference (“the Press Conference”) to announce the

Indictment. Defendants Jennings and Mackler spoke at the press conference about the investigation and the Indictment. (D.I. 5 ¶ 42). After the Indictment, McGuiness filed a Motion to Suppress based on allegedly false statements made in the Probable Cause Affidavit. (Id. ¶ 48). Accordingly, the Delaware Superior Court conducted a Franks hearing. During the Franks hearing, “Defendant Robinson agreed that he included facts in the affidavit of probable cause supporting the search warrant that he knew or

2 The Indictment charged Plaintiff McGuiness with (1) Conflict of Interest; (2) Theft; (3) Non-Compliance with Procurement Law; (4) Official Misconduct; and (5) Act of Intimidation. (D.I. 5, Ex. B). Plaintiffs Gross and MYCG were not indicted. should have known were false.” (Id. ¶ 49). As a result, part of the seized electronically stored information was suppressed. (Id. ¶ 51; see also D.I. 17 at 12). McGuiness trial was conducted in the Delaware Superior Court from June 14, 2022 to June 30, 2022. During trial, Robinson admitted, again, that certain assertions in paragraphs 23 and

24 of the Probable Cause Affidavit were false. (D.I. 5 ¶ 38). Plaintiffs also discovered that Defendants omitted certain exculpatory facts from paragraph 37 of the Probable Cause Affidavit. (Id. ¶¶ 33-34 (referring to D.I. 5, Ex. F)). On July 1, 2022, the jury found Plaintiff McGuiness guilty of Conflict of Interest, Non- Compliance with Procurement Law and Official Misconduct. (D.I. 17 at 12); see also State v. McGuiness, 2022 WL 3971195, at *1, *4-7 (Del. Super. Aug. 30, 2022). Immediately following the jury’s verdict, the trial judge reversed the conviction for Non-Compliance with Procurement Law. Then, following an appeal, the Delaware Supreme Court reversed the charge of Official Misconduct. (D.I. 17 at 12); see also McGuiness v. State, 312 A.3d 1156, 1201 (Del. 2024). McGuiness’s sole remaining conviction is for Conflict of Interest.

II. THE INSTANT ACTION AND MOTION Plaintiffs McGuiness, Gross and MYCG commenced the instant action in this Court on August 15, 2023.3 On October 12, 2023, Plaintiffs filed their Second Amended Complaint (D.I. 5). The Second Amended Complaint alleges two causes of action against Defendants Jennings, Denney, Mackler and Robinson, in their individual capacities. Count I, asserted under 42 U.S.C. § 1983, alleges that Defendants Denney, Mackler and Robinson violated Plaintiff McGuiness’s Fourth Amendment rights by filing a false probable cause affidavit in order to search the invoice

3 The Complaint (D.I. 1) was asserted against Defendants Jennings, Robinson, and Denney. Then, on September 28, 2023, Plaintiff McGuiness filed a First Amended Complaint (D.I. 3) through which Defendant Mackler was added. payments and office video footage. (D.I. 5 ¶¶ 80-96). In other words, Count I is premised on two Fourth Amendment violations (i.e., a search of the payments and a search of the video footage) stemming from an alleged Franks violation. See Franks v. Delaware, 438 U.S. 154 (1978). Count II, asserted under Delaware’s common law, alleges that Defendants slandered Plaintiffs at the Press Conference.4 (D.I. ¶¶ 97-119).

On February 5, 2024, Defendants filed a motion to dismiss Plaintiffs’ Seconded Amended Complaint (D.I. 13) pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. In their Opening Brief (D.I. 14), Defendants argued dismissal was warranted for the following reasons: (1) Count I, as to the search of the invoice payments, was barred by Heck v. Humphrey, 512 U.S. 477

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McGuiness v. Jennings, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcguiness-v-jennings-ded-2025.