Meranelli v. Pruette

Background

Cherrity Honesty-Alexis Meranelli, who represented herself, sued Jesse Ryan Pruette, a security counselor assigned to the Special Services Department at the Minnesota Sex Offender Program, in his official and individual capacities. The dispute concerned Pruette’s alleged disallowance of a transparent lace cover-up. The complaint also named Jane Does and John Does.

Two motions were before the court. Pruette moved for summary judgment, which asks the court to rule because the evidence shows no genuine dispute over a fact that could affect the result. Meranelli moved for permission to amend her complaint nearly one year after the amendment deadline.

Magistrate Judge’s Decisions and Review

On March 25, 2025, the magistrate judge denied Meranelli’s motion to amend and recommended granting Pruette’s summary-judgment motion. Meranelli objected to the recommendation and appealed the order denying amendment.

The district court reviewed the amendment decision for clear error or whether it was contrary to law. It reviewed the summary-judgment recommendation anew. The court concluded that the motion to amend was untimely and lacked the good cause required by Federal Rule of Civil Procedure 16(b). It therefore affirmed the magistrate judge’s denial of that motion.

Merits of the Summary-Judgment Motion

The court accepted the recommendation to grant summary judgment. Meranelli’s claim was a “class-of-one” equal-protection claim based on the denial of the transparent lace clothing item. The court explained that discretionary decisions, including dress-code enforcement in a secure facility, do not support class-of-one claims. It found that the record showed Pruette acted under a uniform policy while exercising discretionary judgment.

The court also found no admissible evidence that a similarly situated person received more favorable treatment and no evidence that Pruette acted with discriminatory intent. It rejected Meranelli’s objections concerning qualified immunity and the failure of her claims for injunctive relief.

Disposition

Judge Jerry W. Blackwell ordered that Meranelli’s appeal and objections be overruled, affirmed the magistrate judge’s order denying leave to amend, accepted the March 25, 2025 Report and Recommendation, and granted Pruette’s motion for summary judgment. The court directed that judgment be entered accordingly.