Treasure Wright v. Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor

CourtDistrict Court, D. Minnesota
DecidedMarch 17, 2026
Docket0:25-cv-03376
StatusUnknown

This text of Treasure Wright v. Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor (Treasure Wright v. Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor) 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
Treasure Wright v. Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor, (mnd 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ________________________________________________________________________ Treasure Wright, File No. 25-cv-3376 (ECT/DTS)

Plaintiff,

v. OPINION AND ORDER

Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor,

Defendants. ________________________________________________________________________ Treasure Wright, pro se.

Carlos B. Soto-Quezada and Jason J. Kuboushek, Iverson Reuvers, Bloomington, MN, for Defendants Swift County, Minnesota and Katie Foley. ________________________________________________________________________ Pro se Plaintiff Treasure Wright contacted Swift County several times in May, June, and July 2025, to purchase tax-forfeited real property. According to Ms. Wright, the County and its then-auditor and treasurer, Katie Foley, did not respond to some of Ms. Wright’s inquiries, took too long to respond to others, gave Ms. Wright inaccurate information, and ultimately prevented Ms. Wright from bidding on or purchasing tax-forfeited property. See Compl. [ECF No. 1] at 1–3. In this case, Ms. Wright claims these actions (1) violated her right to procedural due process under the Fourteenth Amendment; (2) violated her right to equal protection under the Fourteenth Amendment; (3) violated her right to be free from retaliation because of her exercise of First Amendment freedoms; and (4) amounted to government misconduct more generally. Id. at 4. Ms. Wright brings each of these claims under 42 U.S.C. § 1983. Compl. at 4. Ms. Wright brings these claims against Swift County and Ms. Foley only “in her official capacity as Swift County Treasurer/Auditor.” Id. at 1. Ms. Wright alleges that Defendants’ actions caused her emotional distress, damaged her “dignity and trust in fair access to public resources,” caused her financial harms “from

being denied a life-changing property opportunity,” and caused her to incur medical costs. Id. at 5. For relief, Ms. Wright seeks compensatory damages of $3 million; a declaration that Defendants violated her constitutional rights; injunctions that would require Swift County to “restore [its] tax-forfeited land webpage,” offer her “a fair and documented opportunity to purchase tax-forfeited land,” and give her “construction of legal easement

access to any parcel” she purchases; and “reasonable attorney’s fees and costs if legal counsel is retained.” Id. Defendants seek summary judgment under Federal Rule of Civil Procedure 56, and the motion will be granted. No reasonable jury could find that Ms. Wright’s injuries resulted from a governmental policy or custom. Ms. Wright cannot state a cognizable

claim for relief against Swift County without satisfying Monell v. Department of Social Services of New York, 436 U.S. 658 (1978). Monell’s basic rule is “that civil rights plaintiffs suing a municipal entity under 42 U.S.C. § 1983 must show that their injury was caused by a municipal policy or custom.” Los Angeles County v. Humphries, 562 U.S. 29, 30–31 (2010). In other words, a municipality cannot be held liable under § 1983 because

it employed a tortfeasor, but it may be “sued directly under § 1983 for monetary, declaratory, or injunctive relief . . . [only if] the action that is alleged to be unconstitutional implements or executes a policy statement, ordinance, regulation, or decision officially adopted and promulgated by that body’s officers.” Monell, 436 U.S. at 690. The same rule applies to Ms. Wright’s claims against Ms. Foley because she sued Ms. Foley in only her official capacity. “A suit against a government official in his or her official capacity is ‘another way of pleading an action against an entity of which an officer is an agent.’” Baker

v. Chisom, 501 F.3d 920, 925 (8th Cir. 2007) (quoting Monell, 436 U.S. at 690 n.55). “Official-capacity liability under 42 U.S.C. § 1983 occurs only when a constitutional injury is caused by ‘a government’s policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy.’” Gladden v. Richbourg, 759 F.3d 960, 968 (8th Cir. 2014) (quoting Grayson v. Ross, 454 F.3d 802, 810–11 (8th

Cir. 2006)). Ms. Wright has not met the burden Monell imposes. Her Complaint pleads no facts regarding the existence of a policy or policies that might have caused the constitutional violations she alleges. As part of their motion, Defendants explain that their responses (or non-responses) to Ms. Wright’s inquiries resulted—not from any official policy—but from

administrative challenges prompted by the combination of the County’s auditor and treasurer offices. See ECF No. 20 ¶¶ 4–8. These, in turn, “caused administrative delays in all processes, including responding to emails,” the inability to access information regarding tax-forfeited properties through the County’s website, and the listing of some tax-forfeited properties as available “when they had already been sold.” Id. ¶¶ 6–7. In her response to

Defendants’ motion, Ms. Wright neither addresses these explanations nor identifies any facts that might suggest that Defendants’ allegedly unlawful actions were policy-driven in the sense Monell requires. Monell aside, Ms. Wright does not explain or cite evidence showing how Defendants’ treatment of her might conceivably rise to the level of a constitutional violation. She does not identify what process she did not receive that she believes the Fourteenth Amendment required. See Jenner v. Nikolas, 828 F.3d 713, 716 (8th Cir. 2016)

(explaining that, to show a due-process deprivation, a plaintiff must show (1) that Defendants deprived her of a liberty or property interest protected by the Fourteenth Amendment, and (2) that she was deprived of that interest without procedures that were constitutionally sufficient) (citing Swarthout v. Cooke, 562 U.S. 216, 219 (2011) (per curiam)). She does not identify the basis for her equal-protection claim. Is it sex, race, or

something else? She identifies no comparator whom Defendants treated more favorably. See Adam & Eve Jonesboro, LLC v. Perrin, 933 F.3d 951, 959 (8th Cir. 2019) (explaining that the “first step” when evaluating an equal-protection claim is to decide “whether the plaintiff has demonstrated that she was treated differently than others who were similarly situated to her”) (quoting In re Kemp, 894 F.3d 900, 909 (8th Cir. 2018)). She does not

identify what First Amendment-protected activity forms the basis for her retaliation claim. Nor does she connect protected activity to an adverse action. See Bennie v. Munn, 822 F.3d 392, 397 (8th Cir.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Los Angeles County v. Humphries
131 S. Ct. 447 (Supreme Court, 2010)
Grayson v. Ross
454 F.3d 802 (Eighth Circuit, 2006)
Baker v. Chisom
501 F.3d 920 (Eighth Circuit, 2007)
James Gladden, Jr. v. Kenneth Richbourg
759 F.3d 960 (Eighth Circuit, 2014)
Robert Bennie, Jr. v. John Munn
822 F.3d 392 (Eighth Circuit, 2016)
Debra Jenner v. Kay Nikolas
828 F.3d 713 (Eighth Circuit, 2016)
In Re: Honorable John Kemp v.
894 F.3d 900 (Eighth Circuit, 2018)
Adam and Eve Jonesboro, LLC v. Harold Perrin
933 F.3d 951 (Eighth Circuit, 2019)
Jones v. City & County of Denver
854 F.2d 1206 (Tenth Circuit, 1988)

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Treasure Wright v. Swift County, Minnesota and Katie Foley, in her official capacity as Swift County Treasurer/Auditor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/treasure-wright-v-swift-county-minnesota-and-katie-foley-in-her-official-mnd-2026.