Cooley v. Dakota County Jail Kitchen Staff/Medical Staff
- Elizabeth Cowan Wright
- 0:24-cv-02457
- U.S. District Court · District of Minnesota
- 5
In Cooley v. ACH, Judge Wright recommends granting Cooley’s dismissal request and dismissing his claims against ACH without prejudice.
Morye Cooley’s claims against Advanced Correctional Healthcare, Inc. (ACH) would be dismissed without prejudice if the recommendation is adopted. The opinion does not state that Cooley’s claims against Summit are resolved.
What happened
Morye Cooley v. ACH and Summit concerns Cooley’s claims that food served at Dakota County Jail violated his religious rights and was nutritionally inappropriate. He asked to withdraw his claims against Advanced Correctional Healthcare, Inc. (ACH), stating that the issue had been resolved.
Because ACH had already answered, the court treated Cooley’s request as a request for dismissal under Federal Rule of Civil Procedure 41(a)(2). ACH did not oppose dismissal but asked that it be with prejudice, which would prevent refiling.
The court recommends granting Cooley’s motion and dismissing the Amended Complaint as to ACH without prejudice. Judge Elizabeth Cowan Wright concluded that the limited information about the resolution and the unclear status of possible damages and court-ordered relief did not support dismissal with prejudice. The recommendation is not a final order or judgment, and the opinion states that objections may be filed within 14 days after service.
The detailed version
- Cooley v. Dakota County Jail Kitchen Staff/Medical Staff · No. 0:24-cv-02457
- Elizabeth Cowan Wright
- Feb. 5, 2025
Background
Morye Cooley sued multiple defendants, including Advanced Correctional Healthcare, Inc. (ACH), over food service at Dakota County Jail. The opinion states that Cooley alleged the food violated his religious rights and was nutritionally inappropriate for him.
ACH filed an Answer to the Amended Complaint on December 23, 2024. Cooley then sent a letter asking that the allegations against ACH be “vacated” and stating that the issue had been resolved. The court interpreted the letter as a request to dismiss Cooley’s claims against ACH.
Rule 41(a)(2) analysis
Because ACH had filed an Answer, the court determined that Federal Rule of Civil Procedure 41(a)(2) applied. That rule allows a plaintiff to dismiss an action by court order on terms the court considers proper, and generally makes the dismissal without prejudice unless the order says otherwise.
The court considered whether Cooley had adequately explained his request, whether dismissal would waste judicial resources, and whether it would unfairly prejudice ACH. It found that Cooley had provided a proper explanation by stating that his issues with ACH had been resolved. It also found that the case was at an early stage and that ACH would not be prejudiced because ACH did not oppose dismissal.
ACH asked that the dismissal be with prejudice. The court declined to recommend that result because the record provided limited information about why the issue was resolved and did not clearly show whether the parties had reached a complete resolution concerning both injunctive relief and damages.
Recommendation and procedural status
The court recommends that Cooley’s motion to dismiss his claims against ACH under Rule 41(a)(2) be granted. It separately recommends that the Amended Complaint be dismissed as to ACH without prejudice. The recommendation does not resolve Cooley’s claims against Summit in the text provided.
The opinion is a Report and Recommendation, not an order or judgment of the District Court. It states that the recommendation is not directly appealable to the Eighth Circuit and that a party may file specific written objections within 14 days after being served with the recommendation.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.