Beckman v. Samaritan Bethany Senior Home

Background

Karen Beckman, a Certified Nursing Assistant (CNA) working through a healthcare staffing agency called Eshyft, was assigned to Samaritan Bethany Senior Home in Rochester, Minnesota in April 2023. An incident involving her care of a resident was reported to Samaritan's Vulnerable Adult Investigator, who referred the matter to the Rochester Police Department. Beckman was charged with Fourth Degree Assault of a Vulnerable Adult. Olmsted County tried the case to a jury, which returned a not guilty verdict. Beckman was also discharged from her position after the incident.

Beckman filed a charge of discrimination with the U.S. Equal Employment Opportunity Commission (EEOC) on December 9, 2023, alleging racial discrimination against Samaritan Bethany. The EEOC dismissed her charge and issued a right-to-sue letter on June 28, 2024. She then filed a federal complaint, originally in the Northern District of Illinois, which was transferred to the District of Minnesota in September 2025.

Claims Asserted

Beckman's complaint, filed pro se (without a lawyer), asserted ten counts: - Count I: Age discrimination under the Age Discrimination in Employment Act (ADEA), against Samaritan. - Counts II–III: Discrimination and retaliation under Title VII of the Civil Rights Act, against Samaritan. - Count IV: Discrimination under the Minnesota Human Rights Act (MHRA), against Samaritan. - Counts V–VII: Civil rights claims under 42 U.S.C. § 1983 (a federal statute allowing suits against government actors for constitutional violations), against Rochester and Olmsted County defendants. - Count VIII: Civil conspiracy claim under § 1983, against Rochester and Olmsted County defendants. - Count XI and a duplicate Count VII: State law claims for malicious prosecution and intentional infliction of emotional distress.

All defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) — meaning they argued the complaint failed to state a claim on which relief could be granted — on December 15, 2025.

Legal Standards

On a motion to dismiss under Rule 12(b)(6), the court accepts all factual allegations as true and asks whether the complaint states a claim that is "plausible on its face." Bare legal conclusions without supporting facts are insufficient. Although pro se complaints are construed liberally, pro se plaintiffs are still required to comply with substantive and procedural law.

Rulings on Federal Claims

Olmsted County Defendants

Beckman sued the Olmsted County Attorney and two unnamed assistant attorneys in their official capacities only. Official-capacity suits are treated as suits against the governmental entity itself — here, Olmsted County. To hold a municipality liable under § 1983, a plaintiff must plausibly allege: (1) an official policy that caused the constitutional violation; (2) a widespread and persistent custom or practice with the force of law; or (3) a failure to train or supervise reflecting deliberate indifference to constitutional rights. The court found that Beckman alleged none of these — no identified policy, no pattern of misconduct, no policymaker decision. The federal claims against the Olmsted County defendants were dismissed with prejudice.

The court also noted that the Olmsted County Attorney's Office itself is not a legal entity capable of being sued; the proper defendant would be Olmsted County. The court assumed Beckman intended to name the County Attorney and unnamed assistants.

Rochester Police Department

Beckman named the Rochester Police Department as a defendant. The court explained that police departments are not separate legal entities that can be sued under § 1983 — they are subdivisions of the city or county government. The claims against the Rochester Police Department were dismissed with prejudice.

Rochester Police Officers — Official Capacities

To the extent Beckman sued officers Dezell and Rademacher in their official capacities, those claims are treated as claims against the city itself. Because the city (like the police department) is not a proper defendant for these § 1983 claims as pleaded, those claims were dismissed with prejudice.

Rochester Police Officers — Individual Capacities

The officers asserted qualified immunity, which shields government officials from damages liability under § 1983 when their conduct does not violate clearly established law of which a reasonable official would have known. The court applies a two-part test: (1) did the facts establish a constitutional violation, and (2) was that right clearly established at the time.

Beckman alleged that officers concealed and fabricated evidence, violating her Fourth and Fourteenth Amendment rights, and conspired to "frame" her. However, the court found she failed to plead specific facts: she did not identify what evidence was concealed, what statements were false, or who was responsible for any fabrication. While she alleged a video was "deceptively edited," she did not allege who edited it or that the officers knew it had been edited. Her conspiracy claim similarly consisted only of legal conclusions with no specific facts showing a "meeting of the minds" among the alleged conspirators. The court dismissed these individual-capacity claims, though it did so on the ground that no constitutional violation was plausibly alleged rather than expressly reaching the second prong of the qualified immunity analysis.

Claims Against Samaritan — ADEA (Count I)

Both the ADEA and Title VII require a plaintiff to exhaust administrative remedies by first filing a timely charge with the EEOC and receiving a right-to-sue letter. Judicial claims must be "like or reasonably related to" the administrative charges filed. Beckman's EEOC charge alleged only racial discrimination — not age discrimination. Because age discrimination was not part of her charge and could not reasonably be expected to grow out of an investigation into racial discrimination, she failed to exhaust administrative remedies for her ADEA claim. Count I was dismissed with prejudice.

Claims Against Samaritan — Title VII Discrimination (Count II)

Beckman's complaint alleged discrimination based on national origin, but her EEOC charge alleged only race discrimination. The court construed her complaint liberally as asserting a race discrimination claim. Under the McDonnell Douglas burden-shifting framework, a plaintiff without direct evidence of discrimination must plead facts giving plausible support to the prima facie elements: membership in a protected class, qualification for the position, an adverse employment action, and circumstances giving rise to an inference of unlawful discrimination. Beckman adequately alleged the first three elements but failed to plead facts supporting an inference of racial discrimination — specifically, she did not plead that she met Samaritan's legitimate expectations or that similarly situated non-African American CNAs were treated differently under comparable circumstances. Count II was dismissed without prejudice.

Claims Against Samaritan — Title VII Retaliation (Count III)

To state a retaliation claim under Title VII, a plaintiff must allege: (1) engagement in a statutorily protected activity (opposing a discriminatory employment practice or participating in a protected proceeding); (2) an adverse employment action; and (3) a causal connection. Beckman alleged only that she followed through with her report of the incident and requested that security camera footage be reviewed. The court found these actions do not constitute opposition to a discriminatory employment practice. The court also noted that her EEOC charge was filed months after her termination, so she could not allege that the termination was linked to the filing. Count III was dismissed without prejudice.

State Law Claims

The court's only basis for jurisdiction over the state law claims (Count IV under the MHRA, Count XI for malicious prosecution, and duplicate Count VII for intentional infliction of emotional distress) was supplemental jurisdiction under 28 U.S.C. § 1367, which allows federal courts to hear state claims that are part of the same case as claims within the court's original jurisdiction. Because all federal claims were dismissed, the court declined to exercise supplemental jurisdiction over the state law claims and dismissed them without prejudice, leaving them available to be pursued in state court.

Motion for Appointment of Counsel

Beckman moved for appointment of counsel. The court denied this motion as moot. The court noted that pro se litigants have no constitutional or statutory right to appointed counsel in civil cases, and that the issues in this case were not so complex as to warrant appointment.

Disposition

The three defendants' motions to dismiss were granted in part and denied in part: - Dismissed with prejudice: Count I (ADEA), Counts V–VII (§ 1983 constitutional claims). These claims may not be refiled. - Dismissed without prejudice: Counts II and III (Title VII discrimination and retaliation), Count IV (MHRA), Count XI (state malicious prosecution), and duplicate Count VII (state intentional infliction of emotional distress). Beckman may amend and refile these claims, but must cure the deficiencies identified by the court. - Denied as moot: Plaintiff's motion for appointment of counsel. - Denied as untimely: Plaintiff's motion to supplement the record.