Edner v. Redwood County District Attorney's Office
- Susan Nelson
- 0:19-cv-02486
- U.S. District Court · District of Minnesota
- 32
In Edner v. Redwood County District Attorney's Office, Judge Susan Richard Nelson dismissed most of the claims brought by plaintiff Ryan C. Edner against 25 defendants involved in his state criminal case—which lasted nearly a decade before charges were dropped—allowing only the claims against two law enforcement officers, Jason Jacobson and Bostyn Thompson, to proceed.
Pro se civil rights plaintiffs who sue large numbers of government officials, prosecutors, judges, defense attorneys, and law enforcement in connection with state criminal proceedings; the ruling illustrates the broad immunities available to prosecutors (absolute immunity), judges (absolute judicial immunity), and state entities (sovereign immunity), and the limits on suing defense attorneys under § 1983, as well as the pleading standards for conspiracy claims.
What happened
In Edner v. Redwood County District Attorney's Office, Ryan C. Edner, representing himself, sued 25 defendants—including prosecutors, a judge, court staff, law enforcement officers, and defense attorneys—claiming they conspired to violate his constitutional rights during a state criminal case in Redwood County, Minnesota that began in 2015 and ended when the state dropped charges in 2024 because the physical evidence had degraded over time. Edner filed his federal lawsuit in 2019 while the state case was still pending; the federal case was put on hold until the state charges were resolved. After the charges were dismissed, a magistrate judge recommended throwing out the federal lawsuit entirely because Edner missed a deadline to confirm he still wanted to pursue it, but Edner filed an objection saying he did intend to proceed.
The court then reviewed the complaint on its merits to decide which claims, if any, could move forward. The court found that Edner's claims under two federal criminal statutes (18 U.S.C. §§ 242 and 1951) had to be dismissed because those laws do not give private individuals the right to sue—only the government can bring criminal charges. As for his civil rights claims under 42 U.S.C. § 1983 (a federal law allowing people to sue government officials for constitutional violations), the court dismissed claims against the prosecutors because they are shielded by absolute prosecutorial immunity for actions taken as part of prosecuting a case; dismissed claims against Judge Rohland because judges have absolute immunity for actions taken in their judicial role; dismissed claims against defense attorneys (both private and public defenders) because they do not act "under color of state law" as required by § 1983; dismissed claims against the Minnesota State Board of Public Defense because it is a state entity protected by sovereign immunity; and dismissed claims against most law enforcement officials because the allegations were too vague and conclusory to state a plausible legal claim.
Judge Susan Richard Nelson declined to adopt the magistrate judge's recommendation to dismiss the entire case for failure to prosecute, finding that Edner's objection itself showed he intended to continue the lawsuit. She denied Edner's request to stay (pause) the case further. Nearly all 25 defendants were dismissed without prejudice—meaning Edner is not automatically barred from refiling, though many of the dismissals rest on immunity grounds that would likely block future suits on the same claims. Only the claims against Redwood County Sheriff's Department Investigator Jason Jacobson and City of Morgan Police Chief Bostyn Thompson were allowed to move forward at this stage, though the court noted it was skeptical of those claims and that defendants could still seek dismissal later.
The detailed version
- Edner v. Redwood County District Attorney's Office, No. 19-CV-2486 (SRN/LIB), D. Minn
- Susan Richard Nelson, United States District Judge
- August 20, 2025
Background and Procedural History
Plaintiff Ryan C. Edner, proceeding pro se (representing himself without an attorney) and seeking to proceed in forma pauperis (IFP—without paying the filing fee), filed this 56-page federal complaint in 2019 against 25 defendants connected to his state criminal proceedings in Redwood County, Minnesota. Those proceedings began in September 2015 when law enforcement executed a search warrant at the residence Edner shared with his brother Eric J. Edner, discovering drug paraphernalia, marijuana, firearms, a bulletproof vest, and ammunition. Edner was charged with two counts of fifth-degree controlled substance possession, possession of a firearm by a controlled substance user, carrying a weapon without a permit, and committing a crime while wearing a bullet-resistant vest.
The state case stretched nearly a decade due to multiple attorney changes, continuances, Edner's failures to appear, two bench warrants, a competency evaluation, and appeals. Ultimately, the state dismissed all charges in 2024 because the physical evidence (suspected marijuana) no longer had a reportable level of THC after the years of delay.
The federal case was stayed (paused) while the state case was pending, pursuant to the Younger abstention doctrine (a legal principle under which federal courts generally refrain from interfering with ongoing state criminal proceedings), as originally ordered by the district court and affirmed in relevant part by the Eighth Circuit Court of Appeals. After charges were dismissed, Magistrate Judge Leo I. Brisbois ordered Edner to confirm his intent to prosecute within 30 days. Edner missed that deadline. Magistrate Judge Brisbois issued a Report and Recommendation (R&R) recommending dismissal for failure to prosecute under Federal Rule of Civil Procedure 41(b). Edner filed a timely objection, conceding the missed deadline but asserting his intent to proceed.
Ruling on R&R and Stay Request
Judge Nelson declined to adopt the R&R dismissing the case for failure to prosecute, finding that Edner's objection itself demonstrated his intent to litigate. However, she also denied Edner's request to continue staying the proceedings pending a petition for writ of certiorari (a request for the U.S. Supreme Court to review a lower court decision) because that petition concerned a different case, and the state criminal charges giving rise to this lawsuit had been dismissed with no appeal pending.
Preservice Review Under 28 U.S.C. § 1915(e)
Because Edner sought IFP status, the court conducted a preservice review under 28 U.S.C. § 1915(e), which requires courts to dismiss IFP complaints that are frivolous, malicious, or fail to state a claim on which relief may be granted—even before defendants are served. The court applied the Twombly/Iqbal plausibility standard (requiring factual allegations sufficient to raise a right to relief above a speculative level, not merely legal conclusions).
Edner's claims fell into three legal theories: (1) 18 U.S.C. § 242 (criminal civil rights deprivation); (2) 18 U.S.C. § 1951 (federal extortion/Hobbs Act); and (3) 42 U.S.C. § 1983 (civil rights conspiracy).
Claims Under 18 U.S.C. §§ 242 and 1951 — Dismissed
Both are criminal statutes. No private right of action exists under either provision. Only the Executive Branch may bring criminal prosecutions. These claims were dismissed as to all defendants.
§ 1983 Claims by Defendant Category
Category One — Prosecutors (Redwood County District Attorney's Office, Steven Collins, Jenna Peterson-Haler, Kelly Meehan): All dismissed on absolute prosecutorial immunity grounds. Prosecutors are absolutely immune for conduct intimately associated with the judicial process, including initiating charges, presenting the state's case, requesting continuances, and even alleged knowing use of false testimony or suppression of exculpatory evidence. Edner's allegations that prosecutors conspired with law enforcement to draft an illegal warrant or withhold evidence were found to be wholly conclusory—lacking any specific facts showing a mutual agreement or investigative/administrative conduct outside the prosecutorial role that might defeat immunity.
Category Two — Judicial Officers (Redwood County District Courthouse, Judge Patrick Rohland, Patricia Amberg, Jodi Haen): - The Redwood County District Courthouse is a building, not a legal "person" subject to suit under § 1983. Dismissed. - Judge Patrick Rohland has absolute judicial immunity for rulings made in his judicial capacity, including denying motions to suppress, granting continuances, and issuing arrest warrants. Neither error nor malice strips a judge of immunity, and Edner did not contend Rohland lacked jurisdiction. Conclusory conspiracy allegations do not defeat judicial immunity. Dismissed. - Patricia Amberg (court administrator): Edner's only allegation was a conclusory claim that she conspired with Judge Rohland to deprive him of rights by not ensuring his motions were ruled upon. No specific individual actions were alleged. Under § 1983, vicarious liability does not apply; each defendant must be individually linked to a constitutional violation. Dismissed for failure to state a plausible claim. - Jodi Haen (court reporter): Court reporters do not have absolute judicial immunity under Antoine v. Byers & Anderson, Inc., 508 U.S. 429 (1993). However, Edner's allegation—that Haen charged for and provided incomplete/inaccurate transcripts—was dismissed as frivolous because Edner alleged no facts showing how those transcript deficiencies violated his constitutional rights or affected any proceeding outcome.
Category Four — Defense Attorneys (public defenders Joel Solie, Erica Allex, and private attorneys Eric Olson, Ryan Garry, Paul Hunt, Megan Burkehammer; Minnesota State Board of Public Defense): - Private and court-appointed defense attorneys do not act "under color of state law" for § 1983 purposes, including when performing traditional lawyer functions such as communicating with opposing counsel and providing legal advice. Dismissed. - For civil conspiracy claims involving private actors and state actors, a plaintiff must allege specific facts showing a "meeting of the minds" about an unlawful objective. Edner's broad allegations of a 10-year, wide-ranging conspiracy were conclusory. The allegation that public defenders told him a Franks hearing (a hearing to challenge the truthfulness of a warrant affidavit, see Franks v. Delaware, 438 U.S. 154 (1978)) "did not exist" and that prosecutors knew about it was held insufficient to establish a conspiracy. Ex parte (one-sided, without the opposing party) communications with the judge, standing alone, also do not establish a conspiracy absent a promise to secure a particular outcome. Dismissed. - Minnesota State Board of Public Defense: As a state entity, it is entitled to sovereign immunity (Eleventh Amendment protection) from all suits for relief in federal court. Dismissed.
Category Three — Law Enforcement Defendants: - Redwood County Sheriff's Department and City of Morgan Police Department: These entities are not suable under § 1983—sheriff's departments and police departments are generally not juridical entities subject to suit. Dismissed. - Sheriff Randy Hanson and Chief Deputy Mark E. Farasyn: Sued on a supervisory theory. Under § 1983, respondeat superior (holding a supervisor liable simply because a subordinate violated someone's rights) does not apply. Supervisors may be liable only if they directly participated in the constitutional violation or if their failure to train/supervise caused it. Edner made no allegation of direct participation by either supervisor. On failure to train/supervise, Edner failed to plead facts showing either supervisor had notice of a pattern of similar unconstitutional conduct by subordinates—a rigorous requirement. Dismissed. - Deputies Mitch Zimmerman, Mike Campbell, Mike Hubin, and Breckenridge Police Officer Kris Karlgaard: - As to Karlgaard: Edner alleged that Jacobson directed Karlgaard to threaten and intimidate Edner's grandmother with a fraudulent arrest warrant. The court held Edner could not bring claims on his grandmother's behalf; further, verbal threats alone are not actionable constitutional violations under § 1983. Dismissed. - As to Zimmerman, Campbell, and Hubin: Allegations of falsifying police reports, failing to follow procedure, failing to investigate, failing to report misconduct, and improperly interrogating a minor were all found to be conclusory—lacking specific facts about what was falsified, how procedures were violated, or what was improper in the interrogation. Dismissed for failure to state a plausible claim. - Jason Jacobson (Redwood County Sheriff's Department) and Bostyn Thompson (City of Morgan Police Department): Claims against these two defendants were allowed to proceed past preservice review. The court stated it was skeptical of the claims and noted that the state court record may readily dispose of them, but found that without the full state record, dismissal at this stage was not warranted. The court cautioned that defendants may still file a Rule 12(b)(6) motion to dismiss.
Disposition
- R&R recommending full dismissal for failure to prosecute: NOT ADOPTED. - Request for further stay: DENIED. - All defendants except Jacobson and Thompson: DISMISSED WITHOUT PREJUDICE under 28 U.S.C. § 1915(e)(2). - Claims against Jason Jacobson and Bostyn Thompson: ALLOWED TO PROCEED at this stage.
Reviewer note from the AI+
Read the full 32-page opinion on CourtListener, the free public archive maintained by the Free Law Project.