Sanders v. Hennepin County Human Service and Public Health Department

CourtDistrict Court, D. Minnesota
DecidedSeptember 1, 2022
Docket0:22-cv-00727
StatusUnknown

This text of Sanders v. Hennepin County Human Service and Public Health Department (Sanders v. Hennepin County Human Service and Public Health Department) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanders v. Hennepin County Human Service and Public Health Department, (mnd 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Andrea Lee Sanders,

Plaintiff, MEMORANDUM OPINION AND ORDER v. Civil No. 22-727 ADM/JFD

Hennepin County Human Service and Public Health Department, Michael Freeman, Mississippi Department of Human Service, Minnesota Department of Public Safety, and John Doe,

Defendants.

Andrea Lee Sanders, pro se. Christiana Martenson, Assistant Hennepin County Attorney, Hennepin County Attorney’s Office, Minneapolis, MN, on behalf of Defendants Hennepin County Human Service and Public Health Department and Michael Freeman. ________________________________________________________________________

I. INTRODUCTION This matter is before the undersigned United States District Judge on Defendants Hennepin County Human Service and Public Health Department (“Hennepin County”) and Michael Freeman’s (“Freeman”) (together, “County Defendants”) Motion to Dismiss [Docket No. 22], and Plaintiff Andrea Lee Sanders’ (“Sanders”) Motions to Deny Dismissal [Docket Nos. 45, 64]. For the reasons stated below, the County Defendants’ Motion is granted, and Sanders’ Motions are denied. II. BACKGROUND A. Underlying Child Support Cases Sanders has three child support cases in Minnesota state court (the “Child Support

Cases”). See Exs. 1-3 (Register of Actions for Child Support Cases).1 One of the cases involves a child support judgment from the State of Mississippi that has been registered for enforcement in Minnesota. Ex. 2. Sanders has been ordered to pay child support in each of these cases. Ex. 1 at 8; Ex. 5; Ex. 6 at 3. In the Child Support Cases, Sanders has litigated the amount of his child support

payments, the withholding of his income, and the suspension of his driver’s license due to non-payment of child support. In 2016, Sanders moved to modify child support and reinstate his driver’s license. Ex. 1 at 6; Ex. 3 at 5; Exs. 7-8. The court held a hearing at which Sanders argued that his rights to due process had been violated, that the child support orders were unconstitutional, that the separation of powers doctrine had been

violated, that the wage withholding orders were invalid, and that he no longer wished to contract with the Department of Human Services. Ex. 7 at 2, ¶¶ 13-14. The state court denied Sanders’ motion. Ex. 7 at 3, ¶ 1. Sanders has also been involved in state court contempt proceedings related to the Child Support Cases. In 2018, he was found in contempt of court for failure to pay child

support and was ordered to serve 30 days at the Hennepin County Adult Corrections

1 All exhibits are to the Declaration of Christiana Martenson [Docket No. 25]. Exhibits 3, 6, 8, 11, 14, and 16 are filed under seal as Docket Number 26. All other exhibits are filed as attachments to Docket Number 25. Facility. Ex. 12 at 4, ¶¶ 1-2. His driver’s license has been suspended repeatedly for non- payment of child support. Ex. 1 at 2-3; Ex. 3 at 2; Ex. 12 at 3-5; Exs. 13-16. B. Sanders’ 2017 State Court Lawsuit

In July 2017, Sanders filed a civil lawsuit in Minnesota state court (the “2017 Lawsuit”), alleging that Hennepin County and others had violated federal and state law by enforcing Sanders’ child support obligations in the three Child Support Cases. See Ex. 17 (Complaint in 2017 Lawsuit). Sanders alleged that Hennepin County had suspended his driver’s license due to low child support payments and had sent income-

withholding papers to his employer. Id. at 3-4. In March 2018, the state court dismissed the complaint with prejudice. In the complaint, Sanders asked the state court to discharge his child support obligations, income withholding, and arrears; reinstate his driver’s license; refund money he had already paid in child support; and disestablish paternity. Id. at 4-6; Ex. 18 at 3. The court

held that res judicata barred these claims because Sanders had a full and fair opportunity to litigate them in the underlying Child Support Cases. Ex. 18 at 5-7. The court dismissed the remainder of Sanders’ claims for failure to state a claim. On April 26, 2018, Sanders attempted to remove the dismissed 2017 Lawsuit to federal court. See Sanders v. Hennepin Cnty. Human Serv. & Pub. Health Dep’t Child

Support, No. 18-CV-1138 (DWF/DTS), 2018 WL 5067583, at *1 (D. Minn. July 27, 2018). United States Magistrate Judge David T. Schultz issued a Report and Recommendation (“R&R”) finding that removal was improper and recommending that the case be remanded back to state court. Id. at *1. Judge Schultz found that removal was procedurally improper because only a defendant may remove an action from federal to state court, and because the time for removal had passed. Id. The R&R further stated that “what Sanders seems to seek is not so much removal of the now-terminated state-

court action, but either an appeal of the dismissal to this Court or, alternatively, an independent lawsuit brought on largely or entirely the same grounds as the state-court lawsuit.” Id. The R&R explained that “[b]oth would be equally impermissible,” because the Rooker-Feldman doctrine bars cases inviting federal district court review of a state court judgment, and res judicata bars an independent federal lawsuit brought on the same

grounds as the state-court lawsuit. Id. The district judge adopted the R&R over Sanders’ objections. Sanders v. Denver Hum. Serv. of Child Support Enf’t, No. CV 18-1138 (DWF/DTS), 2018 WL 5045777, at *1 (D. Minn. Oct. 17, 2018). Sanders appealed the federal court’s judgment, and the Eighth Circuit summarily affirmed. Sanders v. Hennepin Cnty. Hum. Serv. & Pub. Health Dep’t Child Support,

No. 19-1166, 2019 WL 8325279 (8th Cir. Sept. 5, 2019). Sanders filed a petition for a writ of certiorari from the U.S. Supreme Court, and the Supreme Court denied the petition. Sanders v. Hennepin Cnty. Hum. Serv. & Pub. Health Dep’t Child Support, 140 S. Ct. 2822 (2020). C. Present Lawsuit

On March 3, 2021, Sanders filed this lawsuit challenging Defendants’ efforts to enforce Sanders’ court-ordered obligations in the Child Support Cases. The Complaint alleges that Defendants are “conspiring to enforce void administrative child support orders” against Sanders. Compl. [Docket No. 1] at 18, ¶ 2. It also alleges that Defendants “conspired unlawfully to suspend . . . Sanders’ commercial class A driver’s [license] by virtue of state law.” Id. at 18, ¶ 3; see also id. at 21, ¶ 9. The Complaint further alleges that Defendants “continue to conspire to enforce void administrative

support wage garnishment.” Id. at 19, ¶ 6. It also alleges that Defendants issued “unlawful warrants” that subjected Sanders to “unlawful imprisonment” for failure to pay child support, and that Defendants “coerced” him to sign “administrative adhesion contracting agreements.” Id. at 22-23, ¶¶ 10-11. The Complaint further alleges that the administrative child support process is unconstitutional because it violates the separation

of powers doctrine. Id. at 21, ¶ 9. The Complaint seeks monetary damages, punitive damages, and injunctive relief. Id. at 23-25. It also seeks “reimburs[ment]” of money that was “confiscated” through wage garnishment, and “discharge” of all child support debts. Id. at 24, ¶¶ 5, 7. The County Defendants have moved to dismiss all claims against them based on

lack of subject matter jurisdiction and failure to state a claim. III. DISCUSSION The County Defendants argue that the Court lacks subject-matter jurisdiction under the Rooker-Feldman doctrine, the domestic relations exception to federal court jurisdiction, and the doctrine of Younger abstention. The County Defendants further

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Sanders v. Hennepin County Human Service and Public Health Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanders-v-hennepin-county-human-service-and-public-health-department-mnd-2022.