Lea v. Casey
- John Tunheim
- 0:24-cv-04276
- U.S. District Court · District of Minnesota
- 9
In Lea v. Casey, Judge Tunheim dismissed Clifford Lea’s civil-rights complaint, partly with prejudice and partly without prejudice, and denied his fee-waiver request as moot.
Clifford Lea’s claims were dismissed: the claims against the State of Minnesota and the Minnesota Department of Corrections with prejudice, and the remaining claims without prejudice. His application to proceed without prepaying fees or costs was denied as moot.
What happened
In Lea v. Casey, Clifford Lea, representing himself, sued several people, agencies, and organizations under a federal civil-rights law over events related to his criminal-sexual-conduct conviction. He alleged race and gender discrimination, an unfair arrest, and withholding of evidence, and sought damages and evidence from his former public defender.
The court concluded that claims against the State of Minnesota and the Minnesota Department of Corrections were barred because states and state agencies generally cannot be sued in federal court under these circumstances. It also concluded that Lea’s remaining claims were barred because winning them would call his conviction into question, and that his claim against the public defender separately failed because the defender was not acting as a state official when providing traditional legal representation.
Judge John R. Tunheim overruled Lea’s objection, adopted the magistrate judge’s recommendation, dismissed the state and corrections-department claims with prejudice, dismissed the remaining claims without prejudice, and denied Lea’s application to proceed without prepaying fees or costs as moot.
The detailed version
- Lea v. Casey · No. 0:24-cv-04276
- John Tunheim
- June 3, 2025
Background
Clifford Lea, proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 concerning events connected to his first-degree criminal sexual conduct conviction. The defendants named in the complaint were Gabrielle Casey, The Attic House, Bao Nguyen, the Hennepin County Adult Probation, the Minnesota Department of Corrections, John Grove, the Minnesota Police Department, the State of Minnesota, and Andrew Reiland, identified as a public defender.
Lea alleged that an improper relationship with an Attic House employee led Casey to terminate him from the program and notify his probation officer. He alleged that he was treated differently because of his race and gender, was unfairly arrested for a probation violation, and was denied video footage and phone records by police and his public defender. He sought $67.5 million in damages and an order requiring his public defender to provide the allegedly exculpatory evidence.
Lea also applied to proceed without prepaying court costs and fees. Magistrate Judge Elizabeth Cowan Wright recommended dismissing the complaint and denying that application as moot. Lea objected, and the district court reviewed the properly challenged portions of the recommendation anew.
Court’s Analysis
Claims against the State of Minnesota and the Minnesota Department of Corrections. The court held that these claims were barred by sovereign immunity under the Eleventh Amendment. The court explained that this immunity applies to states and state agencies, that the Minnesota Department of Corrections is a state agency, and that neither the State of Minnesota nor the department had consented to the action. The court also stated that Congress did not remove this immunity when it enacted Section 1983. These claims therefore failed for lack of jurisdiction.
Remaining claims. The court applied the rule from Heck v. Humphrey, which generally prevents a person from seeking damages under Section 1983 when success would necessarily imply that an uninvalidated conviction or sentence is unlawful. The court found that Lea’s allegations—that he was improperly blamed for the sexual conduct underlying his conviction because of his race and gender—would call the basis of that conviction into question. The court found no indication that Lea’s conviction had been reversed, expunged, declared invalid, or otherwise invalidated. The fact that Lea sought money damages did not change the result.
The court added that, even if the Heck rule did not apply to Lea’s claim against Andrew Reiland, that claim still failed because a public defender does not act under state authority when performing traditional legal work for a criminal defendant. The court also noted that Lea’s proposed substitution of the City of Minneapolis for the State of Minnesota would likely fail because the complaint did not allege that an official city policy caused the claimed violation.
Disposition
Judge John R. Tunheim overruled Lea’s objection and adopted the Report and Recommendation. The court ordered:
- The claims against the State of Minnesota and the Minnesota Department of Corrections were dismissed with prejudice for lack of jurisdiction. - The remaining claims were dismissed without prejudice for failure to state a claim. - Lea’s application to proceed in district court without prepaying fees or costs was denied as moot.
The opinion states that dismissal without prejudice allowed Lea to correct deficiencies in the complaint and refile without permission from the court.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.