White Mountain v. Jordan
- Jeffrey Bryan
- 0:25-cv-00164
- U.S. District Court · District of Minnesota
- 4
In White Mountain v. Jordan, Judge Bryan dismissed Ronnie White Mountain’s complaint without prejudice for pleading defects and an improper challenge to his conviction.
Ronnie White Mountain’s civil claims for damages against the named defendants, including claims described as arising under 42 U.S.C. § 1983 and a Bivens action.
What happened
In White Mountain v. Jordan, Ronnie White Mountain filed a 386-page complaint seeking damages for actions he said were unconstitutional and related to his criminal conviction. He represented himself.
The court reviewed a magistrate judge’s recommendation to dismiss the case. It found that the complaint did not clearly provide enough facts to show that the defendants were liable and that a civil damages lawsuit was not the proper way to challenge the validity of White Mountain’s conviction.
Judge Bryan adopted the recommendation and dismissed the complaint without prejudice. The court said White Mountain could not pursue these civil-rights claims because his conviction had not been reversed or otherwise favorably ended.
The detailed version
- White Mountain v. Jordan · No. 0:25-cv-00164
- Jeffrey M. Bryan
- Apr. 30, 2025
Background
Ronnie White Mountain, who represented himself, filed a complaint with 386 pages of exhibits. The court had previously told him that he would be assessed the full statutory filing fee, required an initial partial fee, and warned that the complaint appeared to violate Federal Rule of Civil Procedure 8(a)(2) because it was lengthy and disorganized. The court also warned that a civil lawsuit was not the proper procedural vehicle for challenging the validity of his criminal convictions.
After White Mountain paid the initial filing fee, Magistrate Judge Elizabeth Cowan Wright conducted a preservice review under 28 U.S.C. § 1915A and recommended dismissal. The recommendation identified violations of Rule 8, an improper collateral attack on White Mountain’s South Dakota criminal proceedings, and statute-of-limitations issues.
White Mountain responded with a letter instead of filing formal objections. The district court concluded that he did not identify specific objections to the recommendation. The court stated that any new arguments raised for the first time in the letter were waived, while also construing his filings liberally because he represented himself.
Court’s analysis
The court agreed that the complaint failed to satisfy Rule 8’s pleading requirements. Specifically, it lacked enough factual content for the court to reasonably infer that the defendants were liable.
The court also held that White Mountain’s claims were procedurally improper under the rule from Heck v. Humphrey. White Mountain sought damages for allegedly unconstitutional actions underlying his criminal conviction. The court explained that claims of this kind under 42 U.S.C. § 1983 or a Bivens action cannot proceed unless the conviction has been reversed on appeal or otherwise favorably terminated. The court found that White Mountain had not obtained a favorable termination of his conviction or sentence. Instead, the opinion states that the Eighth Circuit considered and upheld his conviction in 2021.
Ruling
Judge Jeffrey M. Bryan adopted the Report and Recommendation and dismissed Ronnie White Mountain’s complaint without prejudice. The order directed that judgment be entered accordingly.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.