Sinclair v. Benysek

Case

Sinclair v. Benysek and The Minnesota Emergency Medical Services Regulatory Board, No. 25-cv-3880 (KMM/DTS)

Court

United States District Court, District of Minnesota

Judge

Katherine Menendez

Date

February 25, 2026

Background

Plaintiff KeAnn D.R. Sinclair, a pro se litigant (representing herself without an attorney), filed this civil rights lawsuit arising from a November 1, 2024 traffic stop. During the stop, Ms. Sinclair's mother, Kenya Sinclair, was pulled over with Ms. Sinclair's minor son Xavier in the vehicle. Defendant Kristina Benysek, an Emergency Medical Services (EMS) provider who arrived at the scene, allegedly took custody of Xavier and refused to accept contact information that Kenya offered so Xavier could be returned to Ms. Sinclair. Ms. Sinclair called her mother's phone, a state trooper answered, and Ms. Sinclair arrived at the scene approximately five minutes later and retrieved her son. The court noted that a related case filed by Kenya Sinclair, decided by Judge Laura M. Provinzino, also addressed these facts.

Ms. Sinclair named as defendants Kristina Benysek and the Minnesota Emergency Medical Services Regulatory Board. The court noted that as of January 1, 2025, that board's responsibilities were transferred to the Minnesota Office of Emergency Medical Services (OEMS), a state agency established under Minn. Stat. § 144E.011. OEMS filed the motion to dismiss on behalf of both the named board and itself.

Ms. Sinclair brought claims under 42 U.S.C. § 1983 — the primary federal statute allowing individuals to sue government actors for violations of constitutional rights — asserting: (1) violations of substantive and procedural due process under the Fourteenth Amendment, including interference with familial rights; (2) a Fourth Amendment claim for the alleged refusal to return her child; and (3) Minnesota state law claims for deprivation of parental rights (Minn. Stat. § 609.26), failure to report maltreatment of minors (Minn. Stat. § 626.556), and negligence. She sought both money damages and injunctive relief (a court order requiring or prohibiting certain conduct).

Motion to Dismiss Standard

The court applied the Rule 12(b)(6) standard, under which a complaint must allege enough facts to make a claim for relief 'plausible on its face' (Bell Atlantic Corp. v. Twombly). The court must accept alleged facts as true but need not accept bare legal conclusions. Because Ms. Sinclair is pro se, her complaint is entitled to 'liberal construction,' meaning the court interprets it generously to identify any viable legal theory.

Grounds for Dismissal of OEMS

1. Eleventh Amendment Sovereign Immunity: The Eleventh Amendment to the U.S. Constitution bars individuals from suing a state (or its agencies) in federal court without the state's consent or a clear act of Congress removing that immunity. The court found OEMS is a state agency, making it equivalent to the state itself for purposes of this rule. Congress did not abrogate (remove) Eleventh Amendment immunity through § 1983 (Will v. Michigan Dep't of State Police), and Minnesota has not consented to federal suit. The court also noted that the Ex Parte Young doctrine — which allows suits for prospective injunctive relief against individual state officials — does not apply here because OEMS is not an individual official, and Ms. Sinclair did not properly allege such a claim against Benysek in this context. Because sovereign immunity deprives the court of subject-matter jurisdiction (the authority to hear the case at all), the federal claims against OEMS must be dismissed.

2. Failure to Allege Specific Conduct by OEMS: Even if sovereign immunity did not apply, the complaint fails to allege any specific acts or omissions by OEMS that caused a constitutional violation. The complaint merely identifies OEMS as the regulatory and training authority for EMS providers. Under § 1983, a plaintiff must allege what each defendant actually did or failed to do that violated constitutional rights. General regulatory authority is insufficient.

3. Supplemental Jurisdiction Declined Over State Law Claims: Because all federal claims against OEMS are dismissed, the court exercised its discretion under 28 U.S.C. § 1367(c)(3) to decline supplemental jurisdiction (authority over related state claims that do not independently qualify for federal court) over the Minnesota state law claims. The court cited the Eighth Circuit's guidance that when federal claims are eliminated before trial, factors of judicial economy, fairness, convenience, and respect for state courts typically favor sending state claims back to state court.

Disposition of Claims Against OEMS

- All federal claims against OEMS: Dismissed without prejudice for lack of subject-matter jurisdiction. - All state law claims against OEMS: Dismissed without prejudice under 28 U.S.C. § 1367(c)(3).

Dismissal without prejudice means Ms. Sinclair is not permanently barred from pursuing these claims; however, the opinion does not indicate in what forum or under what circumstances she could do so.

Order to Show Cause Regarding Kristina Benysek

The court separately noted that federal procedural rules (Fed. R. Civ. P. 4(m)) require a plaintiff to serve a defendant with the summons and complaint within 90 days of filing. The complaint was filed October 8, 2025, and there is no record that Benysek has been served. The court ordered Ms. Sinclair to submit a written explanation by March 11, 2026 showing good cause for the failure to serve Benysek, and referred further proceedings on this issue to Magistrate Judge David T. Schultz. The court did not dismiss claims against Benysek at this time.