Wong v. Minnesota DHS, No. 14-3415 (8th Cir. 2016)
Annotate this CasePlaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings.
Court Description: Gruender, Author, with Wollman and Beam, Circuit Judges] Civil case - Civil rights. Because Wong served the defendants with a notice of appeal less than 30 days after the Commissioner of the Minnesota Department of Human Services entered an order on his benefits application, and because no undue delay accompanied his initial filing with the district court, the appeal was timely, and the district court erred in dismissing his appeal on this basis; Rooker-Feldman doctrine did not apply and did not bar review of the state agency decision; Minn. Rev. Stat. Section 256.045 which contemplated only state court review of the benefits decision did not bar the federal courts from exercising supplemental jurisdiction over the matter; the district court's decision dismissing the supplemental state-law claim is vacated and the matter is remanded for further consideration; because the state agency's decision on benefits was not final, the district court erred in finding Wong's ADA and Rehabilitation Act claims were precluded; Wong's complaint failed to state a claim for violation of his due process rights as the state's procedures for review satisfied the minimum requirements of the Due Process Clause; since Wong's equal protection claim under Section 1983 is predicated on the same facts as his ADA and Rehabilitation Act claims, the district court did not err in dismissing the Section 1983 claim on the ground that those statutes provided a comprehensive enforcement mechanism. Judge Beam, concurring in part and dissenting in part.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.