Ryan C. Edner v. Jason Jacobson, Redwood County Sheriff's Department, and Bostyn Thompson, City of Morgan Police Department

Summary

The United States District Court for the District of Minnesota overruled Ryan C. Edner’s objections to a magistrate judge’s order concerning a protective order, access to sealed state-court records, and the deadline for defendants to respond to the complaint. Applying the clearly erroneous or contrary-to-law standard under Federal Rule of Civil Procedure 72(a), the court affirmed the magistrate judge’s order. The court also concluded that the objection concerning the response deadline was moot after the state court issued its decision and defendants filed a motion to dismiss.

Holdings

1. Plaintiff's objection to the extension was overruled because the state court's subsequent decision eliminated the asserted risk of open-ended delay, rendering the issue moot.
2. The denial of plaintiff's request for simultaneous disclosure of sealed state-court records was affirmed because plaintiff identified no authority showing that the magistrate judge clearly erred or misapplied the law.
3. Plaintiff's objections seeking modifications to non-determinative factual recitations were overruled because Rule 72(a) permits objections to a magistrate judge's non-dispositive order only on the grounds that the order is clearly erroneous or contrary to law.

Questions Presented

1. Whether the magistrate judge clearly erred or acted contrary to law by extending defendants' deadline to answer or otherwise respond until twenty-one days after the state court ruled on access to sealed records.
2. Whether the magistrate judge clearly erred or acted contrary to law by denying plaintiff's request for an order requiring state officials to provide sealed records simultaneously to both parties.
3. Whether plaintiff's requested modifications to factual recitations concerning his nonappearance at a hearing and his position regarding access to sealed records constituted proper objections under Federal Rule of Civil Procedure 72(a).

Disposition

affirmed