Williams v. Satriano
DeLaQuay Williams v. Christine Satriano, in her individual and official capacity, et al.
- Katherine Menendez
- 0:24-cv-02618
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In DeLaQuay Williams v. Christine Satriano, Judge Katherine M. Menendez adopted a Magistrate Judge's recommendation and partially granted the defendant's motion to dismiss, throwing out Williams's claim for negligent infliction of emotional distress against Satriano while allowing the rest of the lawsuit to continue.
Plaintiff DeLaQuay Williams, whose negligent infliction of emotional distress claim against Defendant Christine Satriano has been dismissed, though Williams's remaining claims against Satriano and other defendants continue. Satriano partially succeeded in having one claim dismissed but remains a defendant in the ongoing lawsuit.
What happened
In DeLaQuay Williams v. Christine Satriano (No. 24-cv-2618), plaintiff DeLaQuay Williams filed an Amended Complaint against defendant Christine Satriano in both her individual and official capacities, along with other defendants. Satriano moved to have Williams's Amended Complaint dismissed. A Magistrate Judge reviewed the motion and issued a written recommendation on February 23, 2026, concluding that the case should be mostly allowed to proceed, but that one specific claim — negligent infliction of emotional distress — should be dismissed.
Neither Williams nor Satriano filed any objections to the Magistrate Judge's recommendation within the required 14-day window, nor in the roughly three additional weeks that followed. Because no party objected, the presiding district judge reviewed the recommendation only for clear, obvious error rather than conducting a full independent review.
Judge Katherine M. Menendez found no error in the Magistrate Judge's recommendation and formally adopted it. As a result, Satriano's motion to dismiss was granted in part and denied in part: Williams's negligent infliction of emotional distress claim against Satriano is dismissed, but all other claims in the Amended Complaint against Satriano remain active.
The detailed version
- Williams v. Satriano · No. 0:24-cv-02618
- Katherine Menendez
- Mar. 31, 2026
Background
Plaintiff DeLaQuay Williams filed an Amended Complaint against Defendant Christine Satriano (sued in both her individual and official capacities) and other unnamed defendants. The nature of the underlying dispute is not described in this order. Satriano filed a Motion to Dismiss (Dkt. 66) directed at Williams's Amended Complaint (Dkt. 56).
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Shannon G. Elkins issued a Report and Recommendation (R&R) on February 23, 2026 (Dkt. 82). A Report and Recommendation is a written proposal from a magistrate judge — a judicial officer who assists the district court — recommending how the district judge should rule on a matter. Judge Elkins recommended that Satriano's Motion to Dismiss be granted in part and denied in part. Specifically, she recommended dismissal of Williams's claim for negligent infliction of emotional distress against Satriano, but recommended that the motion be denied as to all other claims.
Standard of Review
When a magistrate judge issues an R&R, the parties have 14 days to file written objections. If no objections are filed, the district court reviews the R&R only for clear error — a more deferential standard than the full de novo (independent) review that applies when objections are raised. Neither Williams nor Satriano objected within the 14-day period or during the approximately three additional weeks before this order was issued. Accordingly, Judge Menendez applied the clear error standard, citing Nur v. Olmsted County, 563 F. Supp. 3d 946, 949 (D. Minn. 2021), and the applicable procedural rules.
Ruling
Judge Menendez found no clear error in the R&R and formally adopted it in full. The court's order:
- Accepted the R&R (Dkt. 82).
- Granted in part and denied in part Satriano's Motion to Dismiss (Dkt. 66).
- Dismissed the negligent infliction of emotional distress claim against Satriano from the Amended Complaint (Dkt. 56).
The order does not specify whether the dismissal of the emotional distress claim is with or without prejudice. All other claims in the Amended Complaint against Satriano remain pending.
What Remains
The case continues as to Williams's remaining claims against Satriano and any other defendants. The specific nature of those remaining claims is not described in this order.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.