Rannow v. State of Minnesota
- Jeffrey Bryan
- 0:24-cv-04275
- U.S. District Court · District of Minnesota
- 3
In Rannow v. State of Minnesota, Judge Bryan dismissed the complaint without prejudice and denied the application to proceed without fees as moot.
Steven Leo Rannow, the State of Minnesota, Jody Winter, and Tim Walz were affected by the dismissal; Rannow’s proposed additional defendants were affected by the denial of his request to add them.
What happened
Steven Leo Rannow sued the State of Minnesota, Jody Winter, and Tim Walz, alleging that officials unlawfully placed him in correctional facilities, treatment centers, and group homes and wrongly considered him dangerous because he used alcohol.
The court ruled that Rannow’s complaint did not explain how his civil-commitment or conservatorship proceedings violated federal due-process rights or how the conditions imposed on him were unconstitutional. The court therefore dismissed the complaint without prejudice. It also denied Rannow’s request to add defendants because that request did not state a plausible claim.
Judge Jeffrey M. Bryan dismissed the complaint without prejudice and denied Rannow’s application to proceed without paying filing fees as moot. The court directed that judgment be entered.
The detailed version
- Rannow v. State of Minnesota · No. 0:24-cv-04275
- Jeffrey M. Bryan
- Jan. 17, 2025
Background
Steven Leo Rannow filed a complaint against the State of Minnesota; Jody Winter, identified as a judge of McLeod County; and Tim Walz, identified as Governor of Minnesota. Rannow alleged that the defendants had violated his life by placing him in correctional facilities, treatment centers, and group homes “with no chance of leaving.” He also alleged that the defendants erroneously claimed his alcohol use made him dangerous to himself and others.
Rannow applied to proceed without paying filing fees. The court also considered a December 9, 2024 letter in which Rannow asked to add additional defendants.
Legal standard
Under 28 U.S.C. § 1915(e)(2)(B), a court must deny an application to proceed without paying filing fees and dismiss the action if the complaint fails to state a claim for which relief may be granted. The court accepts non-conclusory factual allegations as true and draws reasonable inferences in the plaintiff’s favor. Although complaints filed by people without lawyers are read liberally, they still must allege enough facts to make the claims plausible.
Court’s analysis
The court concluded that Rannow’s short complaint did not establish how the conditions to which he was subject were unlawful. In particular, Rannow did not allege facts showing that the civil-commitment or conservatorship proceedings violated federal due-process rights or that the specific conditions imposed on him violated the Constitution.
The opinion notes that Rannow’s civil commitment had been reviewed as recently as January 22, 2024, by the State of Minnesota Commitment Appeal Panel, which concluded that he continued to be mentally ill and dangerous to the public. The opinion also states that Rannow was represented by counsel in that proceeding.
The court separately concluded that Rannow’s request to add additional defendants did not state a plausible claim against those proposed defendants.
Disposition
The court dismissed Rannow’s complaint without prejudice for failure to state a claim. It denied the application to proceed without paying filing fees as moot. It also denied Rannow’s letter request to add additional defendants. The court ordered that judgment be entered.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.