Jackson v. Schnell

Background

Tony Dejuan Jackson moved for reconsideration of the court’s September 19, 2024, summary-judgment decision and requested a preliminary injunction. The court had granted summary judgment to the defendants after finding that Jackson did not exhaust administrative remedies before filing his case, as required by the Prison Litigation Reform Act. The court also found that Jackson had not identified evidence showing that administrative remedies were unavailable to him. It dismissed his claims with prejudice because the time for exhausting those claims had expired. Judgment was entered on September 20, 2024, and Jackson had filed a notice of appeal.

Arguments

Jackson argued that the Minnesota Department of Corrections had adopted a new grievance system that was unavailable to him until August 2024. He also alleged that inmates at MCF-Stillwater had engaged in constant drug use, including smoking fentanyl, and that toxic smoke remained in the prison because of poor ventilation. He asserted that these conditions created significant health risks for prisoners and correctional officers. He sought a preliminary injunction so he could exhaust complaints about the current conditions through the new grievance system.

Court’s Analysis

The court concluded that the later adoption of a grievance system did not establish that Jackson had exhausted administrative remedies before filing this case in December 2022. The later events also did not show that administrative remedies had been unavailable to him in 2022. The court therefore found that Jackson had not shown the compelling circumstances required for reconsideration of the earlier summary-judgment decision.

The court also denied the request for a preliminary injunction. It explained that a preliminary injunction is intended to preserve the existing situation until the court can decide the claims and provide relief. Because Jackson’s claims had already been dismissed and judgment had been entered for the defendants, the court found that there was no existing situation to preserve. The court further stated that Jackson could not turn this case, which concerned 2022 prison conditions, into new litigation about conditions during the preceding few months, even though the alleged fentanyl smoke and ventilation problems resembled some allegations in his earlier pleadings.

Disposition

The court denied Jackson’s motion for reconsideration and preliminary injunction. The order did not alter the earlier summary judgment, dismissal with prejudice, or judgment in favor of the defendants.