Wong v. Minnesota Department of Human Services, 820 F.3d 922

Background

Eric Wong, disabled by Ehlers–Danlos Syndrome, applied for Minnesota Supplemental Aid (MSA) “shelter needy” benefits; Hennepin County denied the allowance because Wong had not completed a mandatory in-person PCA assessment.
Wong appealed administratively; a human services judge and the Minnesota DHS Commissioner affirmed the denial, concluding the PCA assessment was mandatory and could be provided with accommodations.
Wong served notice of appeal to the Commissioner on time (within 30 days) but filed the original notice and proof of service in federal court after 30 days; he then filed suit in federal district court seeking review and asserting ADA, Rehabilitation Act (RA), and § 1983 claims.
The district court dismissed the complaint, holding (inter alia) the appeal was untimely, Rooker–Feldman barred federal review, the ADA/RA claims were precluded by the administrative decision, and § 1983 claims failed on the merits.
The Eighth Circuit: affirmed dismissal of the § 1983 claims; vacated dismissal of the state-law appeal and the ADA/RA claims; remanded for the district court to decide supplemental-jurisdiction and abstention issues in the first instance.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of appeal under Minn. Stat. §256.045(7) — does the 30‑day limit apply to service only or to both service and filing?	Wong: 30‑day limit applies only to service; filing with the court has no statutory time limit, and he served within 30 days.	DHS/Hennepin County: the statute requires both service and filing within 30 days; Wong’s filing was untimely.	Held: 30‑day limit applies to service only; Wong’s appeal was timely (service occurred within 30 days).
Applicability of Rooker–Feldman to bar federal review of state administrative decision	Wong: Rooker–Feldman does not apply to executive/administrative action; federal court can review.	DHS: federal court lacks authority (Rooker–Feldman) to review state administrative decision.	Held: Rooker–Feldman does not bar review of state administrative action; it applies only to state-court judgments.
Whether Minn. Stat. §256.045 forecloses federal courts from exercising supplemental jurisdiction over appeals from the Commissioner	Wong: state statute does not strip federal courts of supplemental jurisdiction under 28 U.S.C. §1367; federal courts may hear related state-law claims.	DHS: statute confines review to state court and thus precludes federal review; Commissioner’s order is conclusive unless appealed as statute prescribes.	Held: State statute does not eliminate federal supplemental jurisdiction; district court erred to dismiss on that basis and must consider §1367 factors/abstention doctrines on remand.
Preclusion and merits of ADA/RA and §1983 claims (due process & equal protection)	Wong: DHS’s PCA assessment requirement effectively excluded him in violation of ADA/RA; DHS process violations deny due process/equal protection.	DHS: administrative decision is final and preclusive; procedurally adequate process was provided; ADA/RA claims were considered administratively.	Held: ADA/RA and state-law claims were erroneously dismissed as precluded (vacated and remanded). §1983 claims (procedural due process and equal protection) were properly dismissed: procedural due process failed because available administrative process satisfied Mathews v. Eldridge; equal protection claim duplicative of ADA/RA (not cognizable under §1983).

Key Cases Cited

City of Chicago v. Int’l Coll. of Surgeons, 522 U.S. 156 (1997) (federal courts may exercise supplemental jurisdiction to review state administrative decisions when appropriate)
Verizon Md., Inc. v. Pub. Serv. Comm’n of Md., 535 U.S. 635 (2002) (Rooker–Feldman does not apply to review of executive or administrative actions)
Mathews v. Eldridge, 424 U.S. 319 (1976) (procedural due process requires a balancing test; "meaningful" opportunity to be heard suffices)
Barnhart v. Thomas, 540 U.S. 20 (2003) (last‑antecedent rule of statutory construction and its limits)
United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (supplemental jurisdiction covers claims deriving from the same nucleus of operative fact)
Plough v. W. Des Moines Cmty. Sch. Dist., 70 F.3d 512 (8th Cir. 1995) (federal courts give preclusive effect to state administrative factfinding to the same extent as state courts)
Alsbrook v. City of Maumelle, 184 F.3d 999 (8th Cir. 1999) (comprehensive enforcement mechanisms in ADA/RA counsel against parallel §1983 equal protection actions)