Jackson v. Schnell

Background

Tony Dejuan Jackson, who is incarcerated at Minnesota Correctional Facility–Stillwater and is representing himself, brought this civil-rights action under 42 U.S.C. § 1983. The defendants are Paul Schnell, Jo Ann Erickson, and William Bolin. Jackson’s First Amended Complaint challenged restrictions on internet access, the prison grievance process, alleged interference with access to courts through mail delays, alleged retaliation for filing civil-rights cases, and the availability of a Minnesota Department of Health water-testing report. He requested class-action treatment, prospective injunctive relief, and $1.5 million in punitive damages from each defendant.

Motions and recommended dispositions

The court recommends that Jackson’s third Motion to Amend or Supplement Pleadings be denied as futile. The proposed amendments concerned events at the prison in September 2024. The court concluded that the proposed allegations did not state a claim, did not identify which defendants were responsible, and did not show any defendant’s direct and personal involvement in an alleged constitutional violation.

The court recommends that Jackson’s Motion for Preliminary Injunction be denied. Jackson alleged interference with court access, mail, legal-mail procedures, and post-secondary education. The court found no apparent threat of irreparable harm because there were no pending filing deadlines for him to miss.

The court recommends that the defendants’ Motion to Dismiss be granted and that Jackson’s First Amended Complaint be dismissed in its entirety with prejudice. The court relied on Federal Rule of Civil Procedure 8, which requires a short and plain statement showing entitlement to relief, and Rule 12(b)(6), which requires dismissal when a complaint does not state a plausible claim for relief.

The court also ordered that Jackson’s Motion Requesting that the Court Refer This Case to the Department of Justice for Criminal Procedures be denied. It explained that courts cannot initiate criminal prosecutions and that charging decisions belong to prosecutors.

Claims discussed

The court concluded that Jackson did not state a plausible First Amendment claim because the prison’s internet restrictions were reasonably related to legitimate prison-security objectives. The court noted that internet access remained available for approved work, educational, and vocational purposes and that Jackson had not shown a ready alternative to the restrictions.

The court concluded that Jackson did not state a plausible Fourteenth Amendment equal-protection claim because he did not allege facts showing that he was treated differently from similarly situated incarcerated people.

The court concluded that Jackson did not state a plausible access-to-courts claim because he did not allege that the named defendants were personally and directly involved in the mail delays or that he suffered an actual injury to a pending or contemplated legal claim. The court also noted that he had successfully filed documents in this and other cases.

The court concluded that Jackson did not state a plausible retaliation claim because he did not identify which defendants took adverse action, what that action was, or facts showing that it was motivated by his protected activity. His conspiracy claim also failed because the court found that he had not plausibly alleged an underlying constitutional violation.

The court separately found that Jackson had not alleged sufficient facts connecting Schnell, Erickson, or Bolin to the alleged misconduct. Their supervisory positions alone were not enough to establish individual liability under § 1983. The court declined to decide qualified immunity because the complaint did not contain enough facts to state a plausible claim in the first place.

Requested relief

The court recommends denying Jackson’s request for class-action designation because he was proceeding without a lawyer and, under the authority cited by the court, a self-represented litigant cannot represent the claims and interests of other parties in a class action. The court also concluded that his request for prospective injunctive relief was not narrowly drawn to correct a specific federal-rights violation, as required by the Prison Litigation Reform Act.

The court concluded that the Eleventh Amendment barred Jackson’s claims for monetary damages against the defendants in their official capacities because those claims were treated as claims against the State of Minnesota, which had not waived its immunity. The court also concluded that official-capacity damages claims were barred under § 1983 because states and state officials sued in their official capacities are not treated as persons subject to liability under that statute.

Procedural status

This document is a magistrate judge’s Report and Recommendation and Order. The recommendations concerning amendment, preliminary injunctive relief, dismissal, and dismissal with prejudice are recommendations to the district court. The separate order denying the request for criminal referral was entered by the magistrate judge. The notice states that the Report and Recommendation is not directly appealable to the Eighth Circuit and that specific written objections may be filed within 14 days after service.

Classification

This is a procedural order because the complaint was dismissed under Rule 12(b)(6) for inadequate pleading and failure to state a plausible claim. Although the court discussed the apparent constitutional claims, the disposition was based on pleading and gatekeeping requirements rather than a final merits judgment on those claims.