Shelton v. United States Department of Justice

Background

Victor Shelton filed a petition asking the court to issue a writ of mandamus—a court order requiring a federal official or agency to perform a legally required duty. He sought an order compelling the U.S. Department of Justice to investigate civil-rights complaints filed by Shelton and his wife. Shelton’s allegations included claims that Minnesota had manipulated the meaning of “sex trafficking” to target racial minorities unfairly while treating white patrons and prostitutes more leniently. He also alleged violations of the Trafficking Victims Protection Act and the Civil Rights Act of 1964, along with complicity in racial discrimination and misuse of federal funding.

Shelton also filed a separate motion requesting that the court require the Justice Department to investigate. The court noted that Shelton had paid the filing fee but still screened the action under 28 U.S.C. § 1915A because he was incarcerated and sought relief from a governmental entity.

Court’s analysis

The court explained that mandamus is an extraordinary remedy available only when the plaintiff has a clear and indisputable right to the requested relief, the government official has a nondiscretionary duty to provide it, and no other adequate remedy exists. The duty must be a mandatory obligation plainly required by law.

The court concluded that Shelton did not meet these requirements. It relied on the principle that a private citizen has no judicially enforceable interest in whether the government investigates or prosecutes another person. The court therefore found that Shelton had no clear and indisputable right to the investigation he requested. It also concluded that Justice Department decisions about which investigations to pursue are generally matters of agency discretion, meaning the department had no nondiscretionary duty to investigate at Shelton’s request.

Recommendation and next steps

Because the petition failed to state a claim for which the court could grant relief, the court recommended that the petition for a writ of mandamus be DENIED. It further recommended that Shelton’s separate motion be DENIED as moot.

The document is a report and recommendation signed by U.S. Magistrate Judge David T. Schultz, not a final order or judgment of the District Court. The notice stated that the report was not directly appealable to the U.S. Court of Appeals for the Eighth Circuit and that a party could file specific written objections within 14 days after being served with the report.