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Woodward v. Asure

United States District Court, D. Minnesota

August 19, 2019

John Stephen Woodward, Plaintiff,
v.
Sam Asure and Thomas Jackson, Defendants.

          ORDER OF DISMISSAL

          Wilhelmina M. Wright United States District Judge

         This matter is before the Court on Defendant Sam Asure's motion for judgment on the pleadings.[1] (Dkt. 16.) For the reasons addressed below, Asure's motion is granted and Plaintiff's amended complaint is dismissed without prejudice.

         BACKGROUND

         Plaintiff John Stephen Woodward, who was convicted following a 2012 jury trial in Minnesota District Court (Third Judicial District), is currently serving his prison sentence. He brings this action against Sam Asure, an investigator for the Minnesota Department of Corrections at the Minnesota Correctional Facility in Faribault (MCF-Faribault), and Thomas Jackson, an inmate at MCF-Faribault in 2010.

         Police began investigating Woodward in 2010 in connection with a murder-for-hire plot. At that time, Woodward was incarcerated at MCF-Faribault. Jackson, a fellow inmate, assisted during the investigation by recording conversations with Woodward. The investigation of Woodward culminated in a jury trial in 2012. Portions of the recorded conversations between Woodward and Jackson were admitted in evidence at the trial, and the jury convicted Woodward of conspiracy to commit murder in the first degree.

         Woodward subsequently petitioned the Minnesota District Court (Third Judicial District) for postconviction relief, claiming that the state failed to disclose exculpatory evidence contained within the audio recordings of the conversations between Jackson and Woodward. In his postconviction proceedings, Woodward asserted that, based on the conclusions of a forensic firm that he retained to analyze the recordings, a total of 18 minutes of the recordings is missing. Woodward maintained that the missing segments of the recordings contain exculpatory evidence. In the Minnesota postconviction proceeding, the Minnesota District Court denied Woodward's petition without a hearing. After concluding that Woodward could have raised the issue on direct appeal, the Minnesota District Court determined that Woodward failed to prove that the audio analyzed by the forensic firm was the same audio admitted in evidence at his trial and that Woodward's claims that the missing audio segments included exculpatory information were nothing more than conclusory allegations.

         Woodward appealed the Minnesota District Court's denial of his petition to the Minnesota Court of Appeals, arguing that the district court erred by not holding an evidentiary hearing on the issue. The Minnesota Court of Appeals affirmed the Minnesota District Court's decision. The Minnesota Court of Appeals observed that the record indicated that Woodward's trial counsel had received the unredacted version of the audio recordings and was aware that the recordings had been redacted for trial in order to remove lulls in the conversation. Because the state disclosed the unredacted recordings and Woodward's claim was untimely as it could have been raised on direct appeal, the Minnesota Court of Appeals affirmed Woodward's conviction.

         While his appeal of the district court's denial of his petition for postconviction relief was pending before the Minnesota Court of Appeals, Woodward filed this Section 1983 claim, asserting that Defendants violated his civil rights by contributing to the “spoilage” of exculpatory evidence. Asure moves for judgment on the pleadings in the matter pending before this Court.[2]

         ANALYSIS

         Asure advances several grounds for dismissal of Woodward's amended complaint. Because the existence of subject-matter jurisdiction is a threshold matter, the Court addresses Asure's jurisdictional challenge first. See Turner v. Armontrout, 922 F.2d 492, 493 (8th Cir. 1991).

         I. Subject-Matter Jurisdiction

         Asure argues that Woodward's amended complaint is barred by the Rooker-Feldman doctrine. Such a challenge to subject-matter jurisdiction “may be raised at any point in the litigation.” Berger Levee Dist. v. United States, 128 F.3d 679, 680 (8th Cir. 1997). A defendant may challenge the plaintiff's complaint for lack of subject-matter jurisdiction either on its face or on the factual truthfulness of its averments. See Fed. R. Civ. P. 12(b)(1); Titus v. Sullivan, 4 F.3d 590, 593 (8th Cir. 1993). Here, Asure's Rooker-Feldman argument presents a facial challenge to jurisdiction. In a facial challenge, the non-moving party “receives the same protections as it would defending against a motion brought under Rule 12(b)(6).” Osborn v. United States, 918 F.2d 724, 729 n.6 (8th Cir. 1990). As such, the Court accepts as true all factual allegations in the amended complaint and draws all reasonable inferences in Woodward's favor. See Blankenship v. USA Truck, Inc., 601 F.3d 852, 853 (8th Cir. 2010).

         The Rooker-Feldman doctrine provides that “lower federal courts lack subject matter jurisdiction over challenges to state court judgments” except for challenges properly brought in a habeas corpus petition. Mosby v. Ligon, 418 F.3d 927, 931 (8th Cir. 2005) (internal quotation marks omitted). The doctrine bars “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the [federal] district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). This jurisdictional bar applies only after the state-court claim has been finally resolved. Robins v. Ritchie, 631 F.3d 919, 928 (8th Cir. 2011). Final resolution occurs either when the state court issues a final opinion, id. at 927, or when “the state court proceedings have finally resolved all the federal questions in the litigation.” Id. (quoting Federación de Maestros de Puerto Rico v. Junta de Relaciones del Trabajo de Puerto Rico, 410 F.3d 17, 25 (1st Cir. 2005)).

         Woodward filed his federal complaint on November 27, 2018. At that time, Woodward's petition for postconviction relief was on appeal with the Minnesota Court of Appeals. The Minnesota Court of Appeals did not issue a final decision until December 24, 2018, approximately one month after Woodward filed his federal complaint. Because the state-court proceedings were ongoing when Woodward ...


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