Beaulieu v. Jesson

Background

Wallace James Beaulieu is civilly committed to the Minnesota Sex Offenders Program (MSOP). He is a member of the Leech Lake Band of Ojibwe and practices the Native American religion associated with the band. In 2011, while residing at MSOP’s Moose Lake facility, he wore a religious medicine bag over his shirt.

MSOP policies required necklaces, including spiritual items, to be worn under clothing. Beaulieu refused several requests to move the medicine bag under his shirt. Staff issued him four behavioral reports. The reports resulted in a canteen-ordering restriction, lower-dayroom restrictions, or no additional restriction.

Beaulieu sued under the First, Fifth, and Fourteenth Amendments. He challenged the policies as applied to him rather than their facial constitutionality. He initially filed the complaint without a lawyer but later retained counsel.

First Amendment Claim

The court applied the rule that a prisoner or civilly committed person must show that a policy substantially burdens religious practice to establish a free-exercise violation. Beaulieu testified that wearing the medicine bag under his shirt would not affect his religious practice. The court therefore held that the policy did not impose a substantial burden and granted summary judgment on the First Amendment claim.

Due-Process Claims

Beaulieu agreed that his Fifth Amendment due-process claim could not proceed because the federal government was not involved. He did not address his Fourteenth Amendment due-process claim in his response brief, so the court treated that claim as waived. The court granted summary judgment on both due-process claims.

Equal-Protection Claim

Beaulieu alleged that MSOP staff applied the policy differently because of his race and religion. He identified multiple MSOP clients who wore religious necklaces outside their shirts without receiving behavioral reports. Another MSOP client testified that Native American clients faced problems, including reports for wearing medicine bags, that clients from other cultures did not face.

Viewing the evidence favorably to Beaulieu, the court found a genuine dispute of material fact about whether he was treated differently from similarly situated clients. It therefore denied summary judgment on the equal-protection claim to the extent Beaulieu sought injunctive relief against defendants in their official capacities.

Damages and Injunctive Relief

The court noted that official-capacity claims for monetary damages had previously been dismissed. It also ruled that Beaulieu lacked sufficient evidence of a compensable injury for monetary damages against defendants in their individual capacities. His alleged suicide attempt was not related to the behavioral reports, and a psychological evaluation found no injury or treatment need connected to those incidents.

The court concluded that Beaulieu’s request for injunctive relief was not moot because there was a reasonable expectation that the alleged violation could recur. Section 1983 permits injunctive relief against defendants in their official capacities, but not against defendants in their individual capacities. The surviving equal-protection claim therefore concerns only official-capacity injunctive relief.

Disposition

The court granted in part and denied in part the defendants’ motion for summary judgment. It granted the motion on Beaulieu’s First Amendment, Fifth Amendment, Fourteenth Amendment due-process, and individual-capacity equal-protection claims. It denied the motion on the Fourteenth Amendment equal-protection claim only insofar as Beaulieu seeks injunctive relief against defendants in their official capacities.

The court dismissed the First Amendment, Fifth Amendment, and Fourteenth Amendment due-process claims with prejudice. It also terminated Lucinda Jesson as a party.