Yennie v. Walters
0:18-cv-01626
D. MinnesotaNov 15, 2018Background
- Pro se plaintiff Joseph H. Yennie (a self‑styled “American state national” / sovereign‑citizen) sued two Minnesota judges (Walters, Jacobson) and a county prosecutor (Karrie Kelly) challenging state court restraining orders and a subsequent criminal charge for alleged violations of those orders.
- Complaint alleged denial of rights under the Expatriation Act of 1868 and sought dismissal of state actions and monetary damages for false arrest/imprisonment.
- Judicial defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6), asserting lack of subject‑matter jurisdiction (diversity and federal‑question failures), Rooker‑Feldman, Younger abstention, judicial and Eleventh Amendment immunity, and failure to state a claim.
- Public state‑court records established the underlying matters: civil harassment restraining orders and a related criminal case charging Yennie with violating a restraining order; the judges issued restraining orders but did not sign the criminal complaint.
- The magistrate judge recommended dismissal of all claims with prejudice, concluding federal jurisdiction was absent and the judicial defendants were immune.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Diversity jurisdiction | Yennie asserted he is a citizen of a foreign state (expatriated) so federal diversity exists | All parties reside in Minnesota; Yennie’s expatriation claim lacks legal validity | No diversity jurisdiction; complete diversity absent |
| Federal‑question jurisdiction under Expatriation Act | Yennie claimed rights under Expatriation Act of 1868 (is an "American state national") | Expatriation Act does not immunize a person within the U.S. from state law; claim is frivolous | No federal‑question jurisdiction; Expatriation theory rejected |
| Preclusion by Rooker‑Feldman | N/A (Yennie sought to invalidate state court orders/dismiss pending state prosecution) | Federal court lacks jurisdiction to entertain claims that would nullify state judgments | Rooker‑Feldman bars federal review; dismissal required |
| Younger abstention | N/A (sought injunction/dismissal of pending state criminal prosecution) | Parallel state criminal proceeding exists; important state interest; federal defenses available in state forum | Younger requires abstention; federal court should not enjoin/provide requested relief |
| Judicial immunity | Yennie sought damages/injunctive relief based on judges’ issuance of restraining orders | Judges acted in judicial capacity with jurisdiction; immunity shields them from suit | Judicial immunity bars suit against the judges for these acts |
| Eleventh Amendment / official‑capacity damages | N/A (sought relief implicating official acts) | Claims against judges in their official capacities are effectively against the State and barred | Eleventh Amendment bars damages against state officials in their official capacities |
| Failure to state a claim / personal involvement | Yennie alleged harm but did not plead facts showing these judges caused arrest/charge | No plausible allegations of the judges’ personal involvement in the criminal charging/detention | Complaint fails to state a claim against the judges |
| Dismissal with prejudice | N/A | Normally dismissal for jurisdictional defects is without prejudice, but plaintiff’s theories are frivolous and incurable | Complaint dismissed with prejudice as amendment would be futile |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts lack jurisdiction to review state court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (Rooker‑Feldman doctrine explained)
- Younger v. Harris, 401 U.S. 37 (abstention where parallel state criminal proceedings exist)
- Mireles v. Waco, 502 U.S. 9 (judicial immunity is immunity from suit for judicial acts)
- Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (Eleventh Amendment bars suits against states in federal court)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Twombly pleading standard)
- Will v. Michigan Department of State Police, 491 U.S. 58 (state officials sued in official capacity are not "persons" for § 1983 damages)