McDonald v. Minnesota Board of Chiropractic Examiners

Background

Daniel-Jean McDonald is a Minnesota resident who held a chiropractic license issued in 2008. He subsequently operated a practice under names including Infinite Wellness Chiropractic P.A. and later Wellness Natural Healing Center, P.A. The Minnesota Board of Chiropractic Examiners (the Board) sanctioned McDonald multiple times. In 2021, he entered a Stipulation and Consent Order admitting misconduct during the COVID-19 pandemic, resulting in a stayed six-month license suspension. In 2022, he entered a second Stipulation and Consent Order admitting further wrongdoing, and in February 2023 the Board approved a second order with a two-year stayed suspension subject to probationary conditions. In March 2024, the Board's complaint panel found McDonald had violated the second order, lifted the stay, and imposed a five-year suspension with an administrative stay after twenty-four months subject to probationary terms. On March 25, 2025, the Board issued a Notice and Order for a Prehearing Conference and Hearing, with Defendant Christa L. Moseng assigned as administrative law judge and Defendant Michael D. McSherry, Assistant Attorney General, representing the complaint panel.

McDonald says he surrendered his chiropractic license in December 2024 and now operates as a member and representative of a Private Membership Association (PMA), claiming to work in the "private domain." He argues that because he is no longer licensed, the Board has no authority to pursue the contested case proceeding against him.

On August 19, 2025, McDonald filed this pro se (self-represented) federal lawsuit under 42 U.S.C. § 1983 — the federal civil-rights statute that allows individuals to sue state or local officials for violations of constitutional or federal rights — against the Board, McSherry (Assistant Attorney General), Ridge Pidde (Board executive director), and Moseng. McDonald sought injunctive relief (a court order stopping the proceedings), declaratory relief (a court declaration of his legal rights), and compensatory and punitive money damages. The Board, McSherry, and Pidde (Board Defendants) and Moseng separately moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) (lack of subject-matter jurisdiction) and 12(b)(6) (failure to state a claim).

Legal Framework: Younger Abstention

The court focused its analysis on the Younger abstention doctrine, drawn from Younger v. Harris, 401 U.S. 37 (1971). Under this doctrine, federal courts must generally refrain from interfering with certain ongoing state proceedings out of respect for state sovereignty (comity and federalism). Although federal courts ordinarily have an obligation to hear cases within their jurisdiction, Younger created a narrow exception.

Step One: Exceptional Circumstances

Younger abstention applies to three categories: (1) ongoing state criminal prosecutions, (2) civil enforcement proceedings akin to criminal prosecutions, and (3) civil proceedings involving orders uniquely in furtherance of state courts' judicial functions. The court found the Board's disciplinary proceeding qualifies as a civil enforcement proceeding akin to a criminal prosecution because the Board initiated it in its sovereign enforcement capacity, the proceeding followed an investigation, formal charges were filed, and it may result in sanctions against McDonald. The court cited Minnesota Living Assistance, Inc. v. Peterson, 899 F.3d 548 (8th Cir. 2018), in which the Eighth Circuit found a similar Minnesota contested-case administrative proceeding qualified under Younger, and other cases affirming dismissal on Younger grounds in physician and attorney disciplinary proceedings.

Step Two: Middlesex Factors

The Middlesex factors require (1) an ongoing state proceeding that is judicial in nature, (2) the proceeding implicates important state interests, and (3) the state proceeding provides an adequate opportunity to raise federal constitutional challenges. The court found all three satisfied: - There is an ongoing contested case before an administrative law judge. - Minnesota has an important interest in licensing and regulating chiropractic services. - McDonald can raise constitutional arguments before the administrative law judge or on judicial review of the administrative decision in state appellate court under Minn. Stat. § 14.69.

Step Three: Exceptions to Abstention

A court may still hear a case despite Younger if the state statute at issue is "flagrantly and patently" unconstitutional on its face, or if the federal plaintiff demonstrates bad faith or harassment by the state. The court found McDonald's Amended Complaint contained no plausible allegations of bad faith or extraordinary circumstances justifying an exception.

Rulings on Each Category of Relief

Injunctive and Declaratory Relief

Because all three Younger steps were satisfied, the court dismissed McDonald's claims for injunctive and declaratory relief without prejudice.

Damages Claims

When Younger abstention applies to equitable claims, the ordinary remedy for damages claims is a stay (pausing the federal case), not dismissal. However, a court may dismiss damages claims under § 1983 when awarding damages would require the court to first declare unconstitutional a state statute or overturn a state court judgment on a matter of state policy. The court concluded that any damages award here would require it to first declare unconstitutional Minnesota's laws governing chiropractic licensure or contested case procedures, so dismissal without prejudice — rather than a stay — was appropriate for the damages claims as well.

The court also noted two additional grounds that would independently bar damages even if Younger did not apply: - Official capacity claims: The Eleventh Amendment bars damages claims against state officials sued in their official capacities in federal court (sovereign immunity). - Individual capacity claims: Defendants would likely be protected by absolute immunity because they were performing quasi-judicial functions. The court explained that unlike qualified immunity — which can be overcome by showing a violation of clearly established rights — absolute immunity applies without qualification when it applies.

Disposition

Judge Tunheim granted both the Board Defendants' motion to dismiss (Docket No. 7) and Defendant Moseng's motion to dismiss (Docket No. 13). The court abstained under Younger and dismissed the entire action without prejudice. The court explicitly warned that if McDonald refiles and circumstances have not materially changed, the court will likely dismiss again under Younger.

The court also disregarded three unauthorized supplemental memoranda McDonald filed after defendants' replies, because local rules permit only one opposition response to a dispositive motion without prior court approval.