Stefannie Dyson and Sean Wells-El v. Bartolomei
Stefannie Dyson and Sean Wells-El v. Luis Bartolomei, Sarah Lindahl-Pfieffer, Hennepin County District Court 4th District, and The State of Minnesota
- Laura Provinzino
- 0:25-cv-02296
- U.S. District Court · District of Minnesota
- 19
In Dyson and Wells-El v. Bartolomei et al., Judge Provinzino denied the plaintiffs' motion to remove her from the case and dismissed all of their claims against a state-court judge, a court clerk, the Hennepin County District Court, and the State of Minnesota after finding that sovereign immunity, judicial immunity, quasi-judicial immunity, and other legal doctrines blocked the lawsuit.
Pro se (self-represented) litigants who attempt to file documents in a family member's state criminal case and then sue the presiding judge, court administrator, the county court, and the state in federal court over orders restricting such third-party filings. Also relevant to anyone considering a § 1983 suit against state judicial officers or a state itself in federal court.
What happened
In Dyson and Wells-El v. Bartolomei, Lindahl-Pfieffer, Hennepin County District Court 4th District, and the State of Minnesota, two plaintiffs — Stefannie Dyson and Sean Wells-El, who represented themselves — sued over a May 2025 order issued by Minnesota state-court Judge Luis Bartolomei. That order barred anyone other than the actual parties (the prosecutor's office and the defendant, Rajuan M. Jones) from filing documents in Rajuan's criminal case. Dyson is Rajuan's mother; Wells-El's relationship to the case is not stated in the opinion. After the state court and the Minnesota Court of Appeals refused to let the third-party filings proceed, Dyson and Wells-El filed this federal lawsuit seeking money damages and a court order that would vacate the state-court order, compel acceptance of their filings, and reverse Rajuan's criminal sentence.
The plaintiffs brought several types of claims: civil-rights claims under 42 U.S.C. § 1983 (a federal law allowing people to sue government officials for violating their constitutional rights), a "Monell" claim (a theory that a local government is responsible for unconstitutional policies or customs), and state-law claims for fraud and negligence. The plaintiffs also asked Judge Provinzino to step aside from the case because she had previously dismissed an unrelated lawsuit filed by another of Dyson's children. The court rejected that request, finding that disagreement with a past ruling in an unrelated case is not a valid reason for a judge to remove herself. On the merits, the court found that the State of Minnesota could not be sued in federal court due to constitutional sovereign immunity; that Judge Bartolomei was protected from damages claims by judicial immunity because issuing a court order is a core judicial act; that court administrator Sarah Lindahl-Pfieffer was protected by quasi-judicial immunity because she was simply following a judge's order when she rejected the filings; and that the plaintiffs failed to plausibly allege that Hennepin County had an unconstitutional policy or custom.
Judge Provinzino also dismissed the plaintiffs' requests for injunctive relief (court orders compelling action), finding that individual-capacity defendants cannot be ordered to act in their official roles, that judicial immunity extends to injunctive relief claims against Judge Bartolomei, and that a longstanding legal principle generally prevents federal courts from issuing injunctions against state courts and their clerks. Because all federal claims were dismissed, the court declined to rule on the remaining state-law claims and dismissed those without prejudice, meaning the plaintiffs may potentially pursue those claims in Minnesota state court. The entire complaint was dismissed without prejudice.
The detailed version
- Dyson and Wells-El v. Bartolomei, Lindahl-Pfieffer, Hennepin County District Court 4th District, and the State of Minnesota, No. 25-cv-2296 (LMP/JFD) (D. Minn. Nov. 3, 2025)
- Laura M. Provinzino, United States District Judge
Background
Plaintiff Stefannie Dyson, the mother of Rajuan M. Jones (a defendant in a Minnesota state criminal proceeding), filed multiple motions in her son's criminal case despite not being a licensed attorney or a party to the case. On May 23, 2025, state-court Judge Luis Bartolomei issued the "May 23 Order" rejecting her filings and directing court administration to summarily reject any further filings by non-parties. On May 29, 2025, plaintiff Sean Wells-El (whose relationship to Dyson and Rajuan is not specified in the opinion) attempted to file documents in Rajuan's case and was similarly turned away. Rajuan filed a petition for a writ of mandamus with the Minnesota Court of Appeals seeking to compel acceptance of third-party filings; the Court of Appeals denied it on June 25, 2025. Dyson and Wells-El then filed this federal lawsuit on June 2, 2025.
Claims asserted
(1) § 1983 claims for damages and injunctive relief against Judge Bartolomei and court administrator Sarah Lindahl-Pfieffer in both individual and official capacities; (2) a Monell claim (municipal liability under § 1983) against Hennepin County District Court 4th District; (3) a § 1983 claim against the State of Minnesota; (4) state-law fraud and negligence claims against all defendants. Plaintiffs also referenced the Tucker Act, the Administrative Procedure Act, and the Privacy Act but provided no supporting factual allegations for those claims.
Recusal motion
Plaintiffs moved to recuse Judge Provinzino because she had previously dismissed an unrelated lawsuit filed by Dyson's other child, Mark Rozell Jones (Jones v. Hennepin Cnty. Fourth Jud. Dist. Ct., No. 25-cv-125). The court denied the motion. Under 28 U.S.C. § 455, a judge must recuse only where impartiality might reasonably be questioned or where there is personal bias. The court found that mere disagreement with a prior ruling does not warrant recusal under Liteky v. United States, 510 U.S. 540 (1994), and that the two cases (one involving Rajuan's criminal matter, one involving Mark's child-custody dispute) were entirely unrelated. Plaintiffs' characterization of the prior dismissal as a "systematic deprivation of access to courts" was deemed unsupported speculation. The motion to recuse Magistrate Judge John F. Docherty was also denied as moot because the district judge — not the magistrate judge — was deciding the dispositive motion.
Jurisdictional analysis
- Rooker-Feldman doctrine: The court acknowledged the case resembled an attempted appeal of a state-court decision but declined to apply the Rooker-Feldman doctrine because that doctrine only bars suits by parties to the underlying state proceeding. Dyson and Wells-El were not parties to Rajuan's criminal case, so the doctrine did not apply. See Lance v. Dennis, 546 U.S. 459 (2006). - Younger abstention: Defendants raised this doctrine but the court noted it is not truly jurisdictional and found it unnecessary to address given other grounds for dismissal. - Sovereign immunity — State of Minnesota: The Eleventh Amendment bars private suits against states in federal court unless Congress has abrogated immunity or the state has consented to suit. Neither exception applies here: Congress has not abrogated Eleventh Amendment immunity for § 1983 claims (Will v. Mich. Dep't of State Police, 491 U.S. 58 (1988)), and Minnesota has not consented. Sovereign immunity also bars the pendent state-law claims against the State. All claims against the State of Minnesota were dismissed. The court also noted plaintiffs forfeited these claims by failing to oppose this argument in their response brief.
Merits analysis
- Monell claim: Plaintiffs failed to plausibly allege any of the three Monell theories. (a) Official policy: Plaintiffs identified no specific policy; the May 23 Order itself cannot be a "final" municipal policy because Judge Bartolomei's order was subject to reversal by higher courts and he therefore lacked final policymaking authority. (b) Unofficial custom: A single act — the May 23 Order — cannot establish a "widespread and persistent" unconstitutional custom. Bolderson v. City of Wentzville, 840 F.3d 982 (8th Cir. 2016). (c) Failure to train/supervise: Plaintiffs' allegation was a bare legal conclusion without supporting facts, insufficient under Ashcroft v. Iqbal, 556 U.S. 662 (2009). - Judicial immunity — Judge Bartolomei (damages, individual capacity): Judicial immunity bars § 1983 damages claims against a judge except for (1) nonjudicial acts or (2) acts taken in complete absence of jurisdiction. Issuing a court order in an ongoing criminal proceeding over which the court had jurisdiction (Minn. Stat. § 484.01) is a core judicial act. Plaintiffs' argument that the May 23 Order was an "administrative act" was rejected; unlike the personnel decision in Forrester v. White, 484 U.S. 219 (1988), the May 23 Order resolved a dispute between parties — a quintessential judicial function. - Quasi-judicial immunity — Lindahl-Pfieffer (damages, individual capacity): Court clerks acting at a judge's direction or pursuant to court order have absolute quasi-judicial immunity from damages. Rogers v. Bruntrager, 841 F.2d 853 (8th Cir. 1988). Lindahl-Pfieffer rejected Wells-El's filings in direct compliance with the May 23 Order, so she is entitled to this immunity. The court rejected plaintiffs' reliance on Antoine v. Byers & Anderson, Inc., 508 U.S. 429 (1993), because that case addressed court reporters, not court clerks. - Injunctive relief claims: (a) Individual-capacity injunctive relief against Judge Bartolomei and Lindahl-Pfieffer failed because individuals do not hold authority to grant injunctive relief in their individual capacities. (b) Official-capacity injunctive relief against Judge Bartolomei was barred by judicial immunity, which extends to claims for prospective injunctive relief against judicial officials acting in their judicial capacity. Just. Network Inc. v. Craighead County, 931 F.3d 753 (8th Cir. 2019). (c) Official-capacity injunctive relief against Lindahl-Pfieffer: Although the Ex parte Young doctrine normally allows injunctive relief suits against state officers without Eleventh Amendment bar, the Supreme Court has recognized that Ex parte Young does not normally permit injunctions against state courts or their clerks. Whole Women's Health v. Jackson, 595 U.S. 30 (2021). - Remaining § 1983 claims: All § 1983 claims were dismissed; consequently, the § 1983 conspiracy claim was also dismissed because no underlying constitutional deprivation survived. - Other federal statutes (Tucker Act, APA, Privacy Act): Dismissed for lack of supporting factual allegations.
State-law claims
With all federal claims dismissed, the court exercised its discretion under 28 U.S.C. § 1367(c)(3) to decline supplemental jurisdiction over the remaining state-law fraud and negligence claims. Those claims were dismissed without prejudice, preserving plaintiffs' ability to refile them in Minnesota state court.
Procedural note
Plaintiffs filed an unauthorized sur-reply after briefing closed; the court declined to consider it as neither the Local Rules nor any court order permitted it.
Disposition
Plaintiffs' Motion for Recusal (ECF No. 13) DENIED. Defendants' Motion to Dismiss (ECF No. 5) GRANTED. Complaint DISMISSED WITHOUT PREJUDICE in its entirety.
Reviewer note from the AI+
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.