Summary
The United States District Court for the District of Minnesota adopted a magistrate judge’s Report and Recommendation in Clifton Scott Campbell’s civil rights action against the City of Duluth and several officers. The court overruled Campbell’s untimely objection and granted the defendants’ motions to dismiss in part, dismissing specified federal and state-law claims without prejudice.
Topics
Practice areas
Questions Presented
- Whether Campbell's untimely objection to the magistrate judge's Report and Recommendation was entitled to de novo review.
- Whether the Report and Recommendation was clearly erroneous or contrary to applicable law.
- Whether Defendants' motions to dismiss should be granted in part and denied in part.
- Whether Campbell's motions to amend the complaint should be denied.
Holdings
- Because Campbell's objection was untimely and merely repeated arguments presented to and considered by the magistrate judge, the objection was reviewed for clear error rather than de novo review.
- The Report and Recommendation was not clearly erroneous and was adopted.
- Defendants' motions to dismiss were granted in part and denied in part; the specified excessive-force, failure-to-intervene, Monell, individual- and official-capacity, intentional-infliction-of-emotional-distress, and defamation claims were dismissed without prejudice, while dismissal with prejudice was denied.
- Campbell's motions to amend the complaint were denied.
Key quotations
“Objections which are not timely and “merely repeat arguments presented to and considered by a magistrate judge are not entitled to de novo review but rather are reviewed for clear error.””
“In the absence of specific objections, an R&R is reviewed for clear error.”
Factual background
Campbell asserted claims arising from encounters involving Duluth police officers, including excessive force, failure to intervene, and state-law claims for intentional infliction of emotional distress and defamation. The record included body-worn-camera and dash-camera footage that had been presented to and considered by the magistrate judge. The district court's order addresses the sufficiency and disposition of the pleaded claims rather than resolving the underlying factual disputes.
Procedural history
On October 15, 2025, Magistrate Judge Leo I. Brisbois denied Plaintiff's motions to amend and recommended granting in part and denying in part Defendants' motions to dismiss. Plaintiff filed an objection more than three weeks after the fourteen-day deadline, repeating arguments concerning body-worn and dash-camera footage. The district court found no clear error, adopted the R&R, overruled the objection, and dismissed specified claims without prejudice.