DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
143415P.pdf 04/19/2016 Eric Wong v. Minnesota DHS
U.S. Court of Appeals Case No: 14-3415
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [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.