Johnson v. Sullivan
- Katherine Menendez
- 0:23-cv-02249
- U.S. District Court · District of Minnesota
- 2
In Johnson v. Sullivan, Judge Menendez adopted a magistrate judge's recommendation and permanently dismissed the case brought by Paul Edward Johnson after granting defendant Ryan Sullivan's motion for sanctions, based on Johnson's failure to engage with the litigation.
Plaintiff Paul Edward Johnson, whose lawsuit has been permanently dismissed with prejudice following sanctions for failing to participate in the litigation. Defendant Ryan Sullivan, who prevailed on his motion for sanctions.
What happened
In Johnson v. Sullivan (Case No. 23-CV-2249), plaintiff Paul Edward Johnson filed a lawsuit against defendant Ryan Sullivan in the U.S. District Court for the District of Minnesota. According to the court record, Johnson stopped participating in the litigation many months before the final ruling, prompting Sullivan to file a motion for sanctions.
United States Magistrate Judge Leo I. Brisbois issued a Report and Recommendation (R&R) on April 3, 2025, recommending that the court grant the sanctions motion and dismiss the case. Johnson did not file any objections to the magistrate judge's recommendation within the allowed time period. Because no objections were filed, the district court reviewed the R&R only for clear error — a more deferential standard than a full independent review.
Judge Katherine M. Menendez found no error in Magistrate Judge Brisbois's analysis and accepted the R&R in full. Judge Menendez granted the defendant's motion for sanctions and dismissed the case with prejudice, meaning Johnson cannot refile this same lawsuit in federal court.
The detailed version
This order in Johnson v. Sullivan, Case No. 23-CV-2249 (KMM/LIB), was issued by United States District Judge Katherine M. Menendez of the District of Minnesota on August 13, 2025.
The case originated as a civil lawsuit filed by plaintiff Paul Edward Johnson against defendant Ryan Sullivan. The opinion does not describe the underlying claims in detail. Defendant Sullivan filed a Motion for Sanctions (docketed at ECF 42), the basis of which is not elaborated in this order but is addressed in the underlying Report and Recommendation (R&R) issued by Magistrate Judge Leo I. Brisbois on April 3, 2025.
The court noted that Johnson appeared to have not engaged with the litigation for many months prior to the ruling, and he did not file any objections to the R&R within the permitted time period. Under 28 U.S.C. § 636(b)(1) and District of Minnesota Local Rule 72.2(b), when a party files specific objections to an R&R, the district court must review those portions de novo (independently and anew). When no objections are filed, the district court reviews the R&R only for clear error, citing Nur v. Olmsted County, 563 F. Supp. 3d 946, 949 (D. Minn. 2021), Fed. R. Civ. P. 72(b), and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996).
Applying the clear error standard, Judge Menendez found no error — clear or otherwise — in Magistrate Judge Brisbois's R&R and accepted it in full. As a result, the court: (1) granted defendant Sullivan's Motion for Sanctions; and (2) dismissed the action with prejudice. Dismissal with prejudice is a final judgment that bars Johnson from refiling the same claims in federal court. Judgment was ordered to be entered accordingly.
The opinion does not specify the nature of the sanctions imposed beyond the dismissal itself, nor does it detail the underlying claims or the specific conduct that gave rise to the sanctions motion.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.