UNITED STATES COURT OF APPEALS

FOR THE EIGHTH CIRCUIT

David James Carlson

Plaintiff-Appellant

vs.

Case No. 16cv765SRNBRT

Appeal No. 162793

Defendants-Appellees
County of Ramsey,
State of Minnesota
County of Anoka,
State of Minnesota
Independent School District #624 (ISD #624)
White Bear Lake, Minnesota

REPLY BRIEF FOR APPELLANT

DAVID J. CARLSON

TABLE OF CONTENTS
Page
SUMMARY OF THE CASE AND REQUEST FOR ORAL ARGUMENT..5
TABLE OF CONTENTS.2
TABLE OF AUTHORITIES...3, 4
ARGUMENT..6-17
CONCLUSION (RELIEF)...18-21
CERTIFICATE OF SERVICE..22

TABLE OF AUTHORITIES
Page(s)
CASES
Colo. River Water Conservation Dist. v. United States, 428 U.S. 800, (1976).8, 19
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)
..........................................................................................6, 8, 9 18,19, 20
Garcia v. San Antonio Metropolitian Transit Authority, 469 U.S. 528 (1985).8, 19
Hageman v. Barton, No. 14-3665, 8th Circuit .8
Juidice v. Vail 430 U.S. 327 (1977)...9, 19
Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423
(1982).7, 19
New Orleans PUB. Serv., INC. (NOPSI) v. City Counsel, 109 S Ct. 2506 (1989)..8
Quackenbush v. All State INS. Co., 517 U.S. 706 (1996)8
Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923)6, 8, 9, 18, 19, 20
Sprint Communications, INC., v. Jacobs, 690 F 3d 8647, 19
United Mine Workers v. Gibbs, 383 U.S. 715 (1966)16
Younger v. Harris, 401 U.S. 37 (1971)....6, 7, 8, 9, 18, 19

STATUTES
28 U.S.C. 1331: US Code - Section 1331:
28 U.S.C 7332: US Code - Section 7332:
42 U.S.C. 1983: US Code - Section 1983:

OTHER AUTHORITIES
U.S. CONST., Art. III, Section 2:
U.S. CONST., Art VI, Clause 2:
State of Minnesota, Office of the Legislative Auditor. Evaluation Report: Guardians Ad
Litem. (1995)
The Supreme Court of Minnesota.Advisory Task Force on the Guardian Ad Litem
System: Final Report. (1996)
State of Minnesota, Office of the Legislative Auditor: Executive Summary. (1995)
The Supreme Court of Minnesota. Progress Report on Minnesotas Guardian Ad Litem
System in Response to the 1995 Minnesota Legislative Auditors Report. (2004)

SUMMARY OF THE CASE AND REQUEST FOR ORAL ARGUMENT

Appellant David J. Carlson (Carlson v. County of Ramsey et al) appeals the
dismissal of his complaint against defendants, County of Ramsey Minnesota; County of
Anoka Minnesota; and Independent School District No. 624 (ISD #624) (White Bear
Lake, Minnesota).
Appellees violated a number of Carlsons Constitutional and Civil Rights, and
committed additional violations against him under the United States Code.
This case involves substantial federal questions, and presents uniquely and
distinctly federal issues.
Carlson is appealing the decision from the Hon. Judge Susan R. Nelson issued on
15 June, 2016, in the District Court of Minnesota, U.S. Eighth Circuit Court.
Because of the scope of the alleged violations, Carlson requests fifteen minutes
for Oral Argument.

ARGUMENT
The Supremacy of the U.S. Constitution is absolute, and holds sway over judicially
created doctrines limiting access to federal courts.
Carlson continues to assert that there can be no higher law of the land than the
Constitution of the United States of America. The Supremacy of the U.S. Constitution is
the foundation of his case. Yet, none of the Appellees even mention the Supremacy of
the Constitution in their briefs. The Supremacy Clause states:
I.

Constitution Supremacy Clause - Article VI, Clause 2 of the U.S. Constitution:

This Constitution, and the Laws of the United States which shall be made
in Pursuance thereof; and all Treaties made, or which shall be made, under the
Authority of the United States, shall be the supreme Law of the Land; and the
Judges in every State shall be bound thereby, any thing in the Constitution or
Laws of any state to the Contrary notwithstanding.
Article III - Section 2 of U.S. Constitution:
Vests sole authority with Congress to create Law governing federalism.
The structure of the Constitution itself demonstrates that Congress is the body
entrusted with the task of defining the relationship between federal and state
courts.
The Supreme Court does not have the Constitutional Right to present its
own personal opinion regarding the scope of federal and state authority under the
guise of judicial opinion.
Appellees would have the Court believe that the Rooker-Feldman and Younger

Doctrines are the Alpha and the Omega of this case. They are not. Carlson asserts that
the lower courts near exclusive reliance on these doctrines amounts to an error in the
application of law.
Both doctrines are judicially created and a too-heavy reliance on them flies in the
face of the Separation of Powers Clause of the U.S. Constitution. The Constitution,

having vested sole authority with Congress to create law regarding federalism, its
authority cannot be denied, or diminished by the judiciary.
Congress has specifically extended jurisdiction under 42 U.S.C. 1983 to the
federal courts to determine matters involving deprivations of rights secured by the
Constitution. Jurisdiction for Carlsons district court action lies within this provision of
the U.S. Code.
Pursuant to the Separation of Powers Doctrine, the judiciary cannot create
doctrines with a weight equivalent to or greater than the Constitution of the United States
of America. This is the fundamental question presented to this Court, yet none of the
Appellees felt compelled to address the issue in their briefs. Their collective failure to
even acknowledge, let alone address, the Supremacy Clause is a concession of its
absolute supreme nature in our Republic.
Appellee Independent School District No. 624 (ISD #624), hangs its argument on
Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423
(1982), but, Sprint Communications, INC., v. Jacobs, 690 F 3d 864 limits applicability of
Middlesex to criminal matters. Carlsons case is not a criminal matter; therefore
Middlesex cannot be said to govern this case.
Further, the Supreme Court holds in Sprint, supra, that federal courts have an
unflagging obligation to hear cases. Finally, Sprint, supra, was a unanimous decision
handed down by the U.S. Supreme Court to the U.S. 8th Circuit, directing the Court not to
decline jurisdiction under Younger v. Harris, 401 U.S. 37 (1971), merely because a state
court is considering the same subject, as exists in Carlsons district court matter.

In Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985),
the Supreme Court declared that questions of federalism were conclusively committed by
the Constitution to a coordinate branch of government; namely, the Congress.
Thus, the Garcia Court declared federalism issues off-limits to the federal
judiciary. Garcia stands in stark contrast to Younger, and numerous legal commentators
have opined they do not see how Younger can still stand, even if the Supreme Court has
not expressly denounced it.
Further, Rooker-Feldman does not bar jurisdiction over actions alleging
independent claims arising from conduct in the underlined state proceedings. Hageman
v. Barton, No. 14-3665, 8th Circuit; and Carlson asserts that claims he has raised in his
federal complaint are, in many instances, wholly independent from these state
proceedings. Carlsons Constitutional claims, in particular, as well as his claims of civil
rights violations, are but some examples of the independent nature of his claims.
In Colo. River Water Conservation Dist. v. United States, 424 U.S. 800, (1976),
the Supreme Court stated, only exceptional circumstances justify federal courts refusal
in deference to the States. Other cases stand for the principle that abstention abdicates
the federal judiciarys obligation to hear cases under Article III. Quackenbush v. Allstate
Ins. Co., 517 U.S. 706, 716 (1996).
In New Orleans Pub. Serv., INC (NOPSI) v. City Counsel, 109 S. Ct. 2506 (1989),
the Court went so far as to state, our cases have long supported the proposition that
federal courts lack the authority to abstain from the exercise of the jurisdiction that has
been conferred.

Justice Brennan, dissenting in Juidice v. Vail 430 U.S. 327, 346 (1977), felt that a
misplaced attachment to principles of federalism and comity has led to an evisceration of
42 U.S. Code Section 1983.
All of the foregoing cases significantly limit Rooker-Feldman and Younger.
Appellees err in failing to acknowledge that, and appellees further err in placing these
two judicially created doctrines on high, to the point where the Supremacy of the
Constitution loses its due authority. Such a misguided ordering of authority, which
cannot be deemed correct under our constitutional system, results in a denial of federal
court access to citizens who have valid, justiciable constitutional claims.

Carlsons rights as a disabled U.S. combat veteran, along with the immovable object
placed before the state court by the federal agency Department of Veterans Affairs
(VA), takes this matter out of a states interests, and places it squarely within the
purview of the federal courts.
Judge Nelson found a state interest in the domestic relations nature of Carlsons
case, but Appellant asserts that such a state interest is superseded by the federal question
presented through Carlsons status as a United States Armed Forces veteran. As a result
of that unique status, Carlson, as well as all United States veterans, and members of the
U.S. Armed Forces are under the exclusive authority of a federal agency; either the
Department of Veterans Affairs, or the Department of Defense (DOD).
Depending on the specifics of their situation, there is continued interest by the
military in the protection of records. Veterans/Military issues present national rights,
which are not best decided by state courts.

Additionally, due to VAs holding of Carlsons entire U.S. Marine Corps (USMC)
Military Service Records in his veterans file, combined with the fact that he possessed a
Top-Secret Security Clearance from the federal agency, the Department of the Navy,
during his missions in combat zones in Iraq and the Middle East. Some of Carlsons
duties were directed from either USMC, the Department of the Navy, DOD, or Central
Intelligence Agency (CIA).
Accordingly, there exist distinctly federal interests by numerous federal agencies
in protecting the contents of Carlsons records, release of which could possibly endanger
classified, secure, and/or Top Secret information and events. This raises further
substantial federal questions under 28 U.S.C. 1331. Consequently, Carlson makes a
very strong case herein for federal jurisdiction over his claims.
Additionally, due to the unusually transient nature of military service, military
members, veterans, and their families, cross state lines and international borders far more
frequently than the rest of the population. This fact raises federal protection issues under
the Commerce Clause of the United States Constitution, again underscoring the
substantial federal question aspect of Carlsons jurisdictional claim.
Contrary to the assertion of ISD #624, Carlson did not argue that all veterans
matters should be decided in federal court; Carlson specifically argued that his particular
case raises meritorious federal issues deserving of a hearing at the federal district level,
before a jury of his peers.
Aside from any other claims inherent in this case, the fact that the state court was
told by the federal agency, VA, that it has no authority beyond its borders, is highlighted
by the statement from the state court that they have been directly informed by VA

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counsel that state court judges do not have authority over the Department of Veterans
Affairs.
This places an immovable federal obstacle in the matter, one that cannot be
adjudicated outside of the federal court system. In this matter in particular, state court
options either do not exist at all, or have been exhausted.
Carlson avails himself of his civil right not to turn over any and all records, and
the state court continues to deprive Carlson and his young daughters of their right to a
familial relationship. This right of protection is granted to Carlson pursuant to 28 U.S.C
7332 Confidentiality of Certain Medical Records.
Just as all three (3) Appellees ignored the Supremacy of the United States
Constitution, so, too, did they completely ignore the federal issue of veterans and
military records and their place and protection within the federal system.
Appellees Ramsey County and Anoka County are proper parties to this suit due to
extensive county involvement of various agencies and departments within each
county. Neither Ramsey County nor Anoka County can extricate itself from this
matter on the grounds that Carlsons cause of action lies solely against the state.
Anoka Countys involvement extends well beyond the court issuing a Harassment
Restraining Order (HRO) against Carlson. In fact, Anoka County Social Services
Department, and Child Protective Services (CPS) were directly involved as a result of
Carlson, who is a mandatory reporter under Minnesota law, filing a child abuse report
with the Lino Lakes Police Department (LLPD), a department within Anoka County.
Additionally, Carlson also filed a child abuse report with Anoka County Child
Protective Services, another department within the Anoka County government system.
These agencies are not departments of the State of Minnesota.

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Due to the extreme nature of the accusations by Carlsons ex-wife against him,
Anoka CPS had a responsibility, multiple times throughout the process, to thoroughly
investigate both the serious allegations made against Carlson by Mrs. Krista A.
Dickenson, and the serious allegations by Carlson against Ms. Dickensons current
husband, Mr. Andrew Dickenson. The failure to investigate these matters on the County
level deprived Carlson of the opportunity to be vindicated of the allegations against him.
This failure by Anoka County also deprived Carlson of the opportunity to protect his
children.
Just as there was extensive county involvement on the part of Anoka County in
Carlsons case, so also was there significant county involvement in Ramsey County. In
fact, the involvement of Ramsey County was even more extensive.
Ramsey Countys Social Services recommendations from 2008-2012 formed the
basis of Carlsons joint-custody order with Mrs. Dickenson. Further, the GAL, who
operates from Ramsey County facilities, had a responsibility to include those records and
consider them in the custody matter; however, she did not. Additionally, Ramsey County
Social Services Officers also had a responsibility to be involved; however, they were not.
As a matter of fact, Ramsey County Social Services performed a parental
assessment and custody evaluation of both Mrs. Dickenson and Carlson during their
investigation. These county employees made subsequent recommendations that included
joint-legal and joint-physical custody of the couples minor children, as well as equal
parenting time.
No evidence was presented to Ramsey County Family Court at any point during
these proceedings that raised a threat of imminent harm, or imminent danger to the

12

minor children that would have provided legal justification for full removal of the
children, and eradication of Appellants custodial rights, which have been taken since
October 2015 to present day.
Ramsey County Child Support services have also been involved throughout the
matter, due to the fact that Carlson covered the childrens medical care under Minnesota
Care and/or Medical Assistance (MA); therefore, Carlson was entitled to receive child
support from Mrs. Dickenson, although he waived that right throughout the process. At
present day, Ramsey County Child Support office remains involved in the protracted
dispute in Ramsey County Family Court, and has been involved since 2008.
The footprints and involvement of both Ramsey County and Anoka County,
through their various agencies, departments, agents, and employees, cannot be denied.
Therefore, Ramsey County and Anoka County are the proper parties defendant, and the
matter ought not have been dismissed on the grounds that the State was the proper party
rather than the counties.
Guardian ad Litems have been operating as quasi-county actors, as detailed in
numerous Minnesota Legislature and Minnesota Supreme Court reports since 1995.
According to the 1995 Minnesota Office of the Legislative Auditor Executive
Summary, With guardian services organized on a county-by-county basis, Minnesota is
one of 33 states where guardian services are provided locally. However, the
Guidelines do not carry the authority of statute or rule, are not uniformly applied, and are
inconsistent with some court rules related to guardians.
Further, in 2004 the Minnesota Supreme Court issued a Progress Report
detailing what changes to the GAL program had been made in nine (9) years; the

13

progress report echoes many of the inconsistencies and problems found in 1995 that were
still persisting and present throughout the State of Minnesota GAL Program. The
Supreme Court recommended again that guidelines and recommendations from even
1986 Guidelines for Guardian Ad Litem be adopted, once again.
In the 2004 Progress Report, The Minnesota Supreme Court further detailed
the inconsistencies within the Minnesota GAL Program:
With guardian services organized on a county-by-county basis, Minnesota
is one of 33 states where guardian services are provided locally. Minnesotas
existing Guidelines for Guardians Ad Litem (1986) were developed by the
Minnesota Judges Association to assure the quality of guardian services
throughout the state. However, the Guidelines do not carry the authority of
statute or rule, are not uniformly applied, and are inconsistent with some
court rules related to guardians.

Further, the Minnesota Supreme Court found continued role confusion within the
state GAL program:
There is not a universally understood or consistently applied definition of
the appropriate roles and responsibilities for guardians in Minnesota,
leading to frequent confusion and differing expectation. References to
guardian roles and responsibilities are scattered throughout court rules,
statues, case law, and judicial guidelines.

Contrary to what the Appellees would have the Court believe, the fact that a GAL
is paid from a state account does not diminish their county connections. GALS use
county supplies, operate from county buildings, represent county interests, and standards
regarding GALS vary from county to county. There is ambiguity resulting from their
roles, which has caused different county GAL Programs to operate in different ways.
This results in public confusion regarding who the GALS work for, because they are not
in fact regulated in the same way other state actors are.

14

Minnesotas own Legislature and Supreme Court appear to find vagueness and a
lack of clarity in whether the GAL Program operates under state control or county
control.

Minnesotas statewide problems with the GAL Program necessitate federal court
involvement. No adequate state remedy exists for addressing extensive systemic
problems.
The forgoing conclusions, from two different branches of Minnesotas
government, argue strongly for federal review of statewide systemic problems that
Minnesota has shown it cannot correct on its own. Carlson reasserts his request for
injunctive relief; specifically, Carlson requests that the federal Department of Justice
(DOJ) conduct an investigation of the GAL Program forthwith. Further, Carlson
reasserts his request that the federal courts oversee a comprehensive correction of
Minnesotas GAL Programs problems.
Supplemental Jurisdiction is appropriate regarding Carlsons claims against ISD
#624.
Supplemental Jurisdiction is appropriate when a claim is anchored to a claim over
which federal jurisdiction was appropriate. Carlson has shown a common nucleus of
operative fact between the actions of ISD #624, and his claims against Ramsey County
and Anoka County.
The actions of ISD #624 employees are inextricably connected with the
recommendation made by the GAL in Ramsey County, which recommendation formed
the basis of Ramsey Countys Family Court Orders. Carlsons claim against ISD 624 is
inseparable from the rest of this matter. Further, the principle of judicial economy

15

demands that Carlsons claims against ISD #624 be heard in conjunction with his claims
against the other two Appellees.
When the entire action before the federal court comprises a single Constitutional
case, the Court may, under Article III, exercise jurisdiction over the entire action,
including any state law claim. United Mine Workers v. Gibbs, 383 U.S. 715 (1966).
Carlson has raised valid and justiciable federal claims under 42 U.S.C. 1983,
and has also raised valid and justiciable federal claims under 28 U.S.C. 1331.
Additionally, Carlson has raised valid and justiciable federal claims under 28
U.S.C. 7332.
Therefore, because of the common nucleus of operative fact connecting his claim
against ISD #624 with his claims against Ramsey County and Anoka County, Carlson is
entitled to have his claim against the school district heard at the same time.
The brief of ISD #624 repeatedly misstates and mischaracterizes the facts in this
matter. Particularly, Appellees brief implies that mental health records of Mrs. Krista
Dickenson were ordered by the Ramsey County Family Court in this matter.
Mrs. Dickensons mental health records have never been requested by the GAL or
Ramsey County Family Court. Carlson is the only party in the Ramsey County Family
Court matter ordered to release medical or mental health records.
Further, ISD #624 misstated the fact that Carlson refused to release his
psychological evaluation results on the grounds that he is a veteran. The record makes
crystal clear that Carlson directed Dr. James Tuorila, PhD to release the evaluation results
to the GAL, and Dr. Tuorila did release the results to the GAL.

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Additionally, Dr. Tuorila lists the diagnostic areas that the VA has deemed
service connected for Appellant. However, Narcissistic Personality Disorder is not one
of those areas he lists; nor is Carlson service connected from VA for Narcissistic
Personality Disorder and never has been. ISD #624s brief misstates this important fact.
Another misstatement by ISD #624 counsel is that Carlson committed to signing
a release for his medical records before the Ramsey County Family Court. Carlson
unequivocally did not commit to releasing his VA medical records.
Not only did ISD 624 misstate and mischaracterize the facts, they went so far as
to insert the word voyeurism into the fact section of their brief. There is absolutely
nothing whatsoever in the factual record of this matter that would justify the inclusion of
a term that is pejorative, insulting, offensive, and wholly without legal justification.
The use of the word voyeurism implies that an act of moral turpitude was
committed by Carlson, when not only is that factually false, but there is not an iota of a
suggestion in the factual record that it could be anything but false.
This conduct on the part of counsel for ISD #624 is intentional and abhorrent. It
calls for sanctions from the Court.
The implication raised by counsel has the potential to cause grave damage to
Carlsons professional career as a schoolteacher, and cause grave damage to his good
name in the community. Counsels conduct is unprofessional, grossly improper, and
egregiously wrong. Such conduct by an Officer of the Court is simply not decent.

End of Page

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CONCLUSION
Carlsons case highlights the problems that result when judicially created
doctrines are allowed to take precedence over the United States Constitution, which is the
Supreme Law of the Land. Article III, Section II, of the U.S. Constitution is not in any
way ambiguous; it vests sole authority in Congress to create law governing federalism.
The authority is not shared, nor can it be diminished in any way, without flying in
the face of the Constitution itself. Further, Article VI, Clause II, of the U.S. Constitution
states that the Constitution shall be the Supreme law of the land. It further states, Judges
in every state shall be bound thereby. This Constitutional mandate goes on to state that
this is true, notwithstanding the Constitution or laws of any state to the contrary.
Accordingly, in the guise of a judicial opinion, courts do not have constitutional
authority to present their own personal opinions regarding the scope of federal and state
authority.
Consequently, the judicially created doctrines of Rooker-Feldman and Younger
are seriously flawed, and they cannot be allowed to act as a legal bar to Carlsons access
to the federal District Court of Minnesota.
Rooker-Feldman and Younger are non-statutory in nature. Under the Separation
of Powers Doctrine, the judiciary is prohibited form executing a power that is solely
delegated to Congress by the Constitution.
It is interesting to note that the judiciary itself has limited applicability of RookerFeldman. The United States Supreme Court has not barred a case under Rooker-Feldman
in 33 years. In fact, it has only mentioned the doctrine three (3) times in the past 15

18

years. The doctrines explosive growth in the federal district courts runs afoul of the
Supremacy Clause and the Separation of Powers Doctrine.
Even if the Court were to accord weight to Rooker-Feldman, numerous decisions
within the past 30 years have severely limited the doctrine. Middlesex, supra, Sprint,
supra, and Garcia, supra, are but a few examples that Carlson has previously cited.
Additionally, Colo. River Water Conservation Dist., supra, stands for the
principle that only exceptional circumstances justify a federal courts refusal in
deference to the states.
Supreme Court Justice Brennan was so concerned about the growth of arguably
bad jurisdictional law that he went so far as to state in Juidice v. Vail, that such law
Eviscerated Section 1983.
Another Supreme Court Justice, John Stevens, feared such an attachment to
judicially created doctrines downgrades the role of federal courts in vindicating federal
rights.
Carlson came to the District Court of Minnesota armed with a federal cause of
action, which includes a set of rights granted to him under the U.S. Constitution. In
closing the door to Carlson, the District Court interposes neither the Constitution nor
Congressional law, but the Courts own ideas of comity and federalism. This flouts the
will of Congress in an area over which it has sole authority under the Constitution.
The Younger Abstention Doctrine is flawed in a different way. It runs afoul of
the Separation of Powers Doctrine to the extent that, under the doctrine, courts make
laws regarding federal jurisdiction that are completely at odds with Congressional
statutes.

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For the Courts to develop and impose a body of jurisdictional law, as it has under
Rooker-Feldman, is to improperly exceed the judiciarys constitutional bounds. Further,
it trespasses on the Legislatures domain.
Judicial emphasis on judicially created doctrines cannot supersede the
Constitutions grant of authority to Congress for legislating the law on federal
jurisdiction.
Carlson has raised justiciable federal issues regarding his status as a U.S. Armed
Forces veteran. State Courts have no authority beyond their borders. When the power of
a state court conflicts with the authority of a federal agency, the Department of Veterans
Affairs, over records it is legally compelled to protect, a federal district court becomes the
only proper venue for the conflict to be adjudicated.
The issues presented by Carlson regarding his confidential federal records have
implications on a national basis, pursuant to the Commerce Clause of the United States
Constitution. No state court is vested with the authority to make a final determination
regarding federal records.
To expect Carlson and his children to continue to live in complete separation from
one another, without access of any kind, because of a conflict of authority between the
state court and a federal agency is unconscionable, and violates fundamental principles of
equity and justice.
Further, such an abhorrent consequence violates Carlsons rights to parent, a right
that has been deemed fundamental under the penumbra of privacy rights afforded by the
First Amendment of the United States Constitution.

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Carlson, as a result of the federal district courts decision, is left in an untenable

position; without access to the federal district court to present his claims, he has nowhere
else to go. This Court ought not stand by and allow his family to be destroyed.
This court has a duty under the Constitution and under the United States Code, to
open the district courthouse doors to Appellant. All he is asking for is his day in court,
his opportunity to be heard by a jury of his peers. Carlson respectfully asks this court to
open the doors of justice and equity to him and his children.

Dated: 26 September 2016

Respectfully Submitted,

Signature of Party

_________________________________________

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CERTIFICATE OF SERVICE
I certify that on 26 September, 2016, the Reply Brief of Carlson David J. Carlson
was filed with the Clerk of the Court by the United States Court of Appeals for the
Eighth Circuit by using the appellate CM/ECF system.
The following participants in the case are registered on CM/ECF users, and will
be served by the appellate CM/ECF System:
Mr. Scott Thomas Anderson
RUPP & ANDERSON
SUITE 1200
527 Marquette Avenue, S.
Minneapolis, MN 55402
Ms. Kristin C. Nierengarten
RUPP & ANDERSON
SUITE 2800
333 S. Seventh Street
Minneapolis, MN 55402
Mr. Andrew T. Jackola
ANOKA COUNTY ATTORNEYS OFFICE
Suite 720 2100 Third Avenue
Anoka, MN 55303-0000
Mr. Robert B. Roche
RAMSEY COUNTY ATTORNEYS OFFICE
Suite 4500
121 Seventh Place, E.
Saint Paul, MN 55101
Mr. Richard Sletten
U.S. DISTRICT COURT
District of Minnesota
202 U.S. Courthouse
300 S. Fourth Street
Minneapolis, MN 55415-0000

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