Lee v. State of Minnesota Bureau of Criminal Apprehension

Background

United States Magistrate Judge Dulce J. Foster issued a Report and Recommendation on January 7, 2025, recommending dismissal of Abraham Sigurd Lee’s complaint without prejudice. Lee filed a timely objection. Because Lee represented himself, the court interpreted his objection liberally.

Lee’s complaint was largely framed as alleging wrongdoing by the State of Minnesota Bureau of Criminal Apprehension (BCA). The complaint briefly referred to employees who allegedly ratified the challenged policy and actions, but it did not identify those employees as defendants. It described the BCA as the entity sued and as the entity that required and initiated the ten-year registration for violent offenders.

Objection and Analysis

The court reviewed the portions of the recommendation to which Lee made specific objections independently and reviewed the remaining portions for clear error. The court found that most of Lee’s objection merely repeated the constitutional claims in his complaint rather than identifying a specific error in the recommendation.

Lee appeared to challenge the finding that the BCA was the only defendant. He asserted in his objection that the complaint sued the BCA’s director, chief executive officer, or an equivalent official under a John Doe or Jane Doe name. The court found that no such person was identified in the complaint. It also held that Lee could not add new pleading details through an objection to the recommendation. The court concluded that the complaint sufficiently identified only the BCA as a defendant.

The court further stated that the BCA entity is immune from suit under Section 1983, the federal law that permits claims against certain state actors for violating constitutional rights. The court said Lee could start a new case naming the individuals who caused or contributed to the alleged constitutional violation, even if their names were not yet known, but any John Doe or Jane Doe pleading would need specific allegations describing each person’s involvement.

Disposition

Judge Jerry W. Blackwell overruled Lee’s objection, accepted the January 7, 2025 Report and Recommendation, and dismissed Lee’s complaint without prejudice. The court also denied Lee’s application to proceed in district court without prepaying fees or costs as moot. The order directed that judgment be entered accordingly.