Karsjens v. Minnesota Department of Human Services

Background

The plaintiffs are fourteen individuals civilly committed to the Minnesota Sex Offender Program under Minnesota law. They represented a class consisting of all patients currently civilly committed to that program. They challenged the constitutionality of the Minnesota Civil Commitment and Treatment Act, both on its face and as applied, as well as aspects of the program’s operation and treatment regimen.

The case began in 2011 and involved a six-week trial, multiple orders, and multiple appeals. The district court initially ruled for plaintiffs on two counts, finding that the program was unconstitutional and ordering relief. The Eighth Circuit later reversed that ruling and entered judgment for defendants on those counts. After further proceedings, the district court dismissed other claims, some with prejudice, and granted defendants’ motion for summary judgment on additional claims. The Eighth Circuit later reversed the dismissal of three counts, but after remand the district court dismissed the remaining claims with prejudice, and the Eighth Circuit affirmed. The Supreme Court denied review.

Bill of Costs and Objection

Defendants requested $837,926.13 in costs under 28 U.S.C. § 1920 and Federal Rule of Civil Procedure 54(d). Plaintiffs objected. They argued that they brought the action in good faith and could not pay the requested amount.

The court explained that costs are generally allowed to a prevailing party, but the court has substantial discretion to deny them when an award would be inequitable. Relevant considerations included whether the claims were brought in good faith, whether the case involved matters of public importance, whether imposing costs could discourage future civil-rights actions, and whether the plaintiffs could pay.

Court’s Analysis

The court found that plaintiffs’ claims were brought in good faith and were not frivolous. The litigation involved difficult and close issues, lasted many years, required a lengthy trial, and included multiple appeals. The court also found that the case raised issues of great public importance because it affected more than 700 people and concerned the constitutionality of statutes governing civil commitment and treatment.

The court further considered plaintiffs’ financial circumstances. The named plaintiffs remained involuntarily committed to the program, and the court found it unlikely that they would be released in the near future. When the action began, plaintiffs reported monthly earnings ranging from $0 to $933, with most earning less than $200 per month. The court found no reason to believe those figures had substantially changed and concluded that plaintiffs were unlikely to be able to pay the requested costs either currently or in the future.

The court concluded that awarding more than $800,000 in costs would impose undue hardship and could have a chilling effect on future litigants. It determined that denying costs was fair and equitable under the circumstances.

Order

Judge Donovan W. Frank sustained plaintiffs’ objection to defendants’ Bill of Costs. The court denied the Bill of Costs, ruled that defendants were not entitled to costs, and directed the clerk to enter the cost judgment accordingly.