Grande v. Hennepin County Sheriffs Dept.

Background

Patrick Ryan Grande sued Hennepin County Sheriffs Dept.; Crawford, Deputy - Badge 251; Minnesota Security Hospital; Malinda Henderson, Nurse Practitioner; State of MN; and Dept of Human Services. He also applied to proceed without paying filing fees. The matter came before the court on United States Magistrate Judge Shannon Elkins’s February 13, 2025 Report and Recommendation, which recommended dismissal under 28 U.S.C. § 1915(e)(2)(B) for failure to state a claim upon which relief could be granted.

Objections and Review

Grande did not formally object to the Report and Recommendation. He later submitted a letter, a document titled an amicus brief submitted by his cousin, and attached exhibits. The court found that these filings did not expressly identify objections and were difficult to follow. To the extent they presented additional facts, the court treated them as an attempted amendment to the complaint. The court explained that new defendants or factual allegations could not be added through a response to the Report and Recommendation or through an amicus brief; applicable rules for amended pleadings had to be followed.

Because Grande made no specific objections, the court reviewed the Report and Recommendation for clear error rather than conducting a fresh review of disputed issues. The court found no clear error.

Court’s Analysis

The court agreed that, under sovereign immunity—a legal protection that generally prevents certain claims against a state and its agencies—the State of Minnesota and the Department of Human Services were not subject to Grande’s claims under 42 U.S.C. § 1983. The court also agreed that the complaint did not include allegations detailed enough to plausibly state a claim for relief.

Disposition

The court adopted the Report and Recommendation. It denied Grande’s application to proceed without paying filing fees as moot and dismissed the matter without prejudice. The order directed that judgment be entered accordingly.