Navratil v. Johnston

Background

The four named plaintiffs—Ryan Navratil, Nicholas Luhmann, Paul Knutson, and Christopher Malz—are civilly committed (meaning they are held under a civil, not criminal, order) to the Minnesota Sex Offender Program ("MSOP"), a state program providing sex offender treatment. Between August 2024 and January 2025, each plaintiff received an order from a Commitment Appeal Panel ("CAP"), a state review body, authorizing transfer from a more secure MSOP facility to a less-secure Community Preparation Services ("CPS") facility. Despite these orders, none had been transferred. Plaintiffs filed a class action complaint in March 2025 against Nancy Johnston, Executive Director of the MSOP, and Shireen Gandhi, Temporary Commissioner of the Minnesota Department of Human Services, in their official capacities only.

Plaintiffs alleged that defendants violated their procedural due process rights under both the Fourteenth Amendment of the U.S. Constitution and Article I, Section 7 of the Minnesota Constitution by failing to transfer them to CPS within a reasonable time. The court noted it had addressed nearly identical issues in a parallel case, Rud v. Johnston, No. 23-486, and relied on rulings from that case extensively.

Defendants' Motion to Dismiss

Defendants filed a motion to dismiss in April 2025 under three procedural rules:

Rule 12(b)(6) — Failure to State a Claim

A Rule 12(b)(6) motion argues that even if everything in the complaint is true, the plaintiff has not stated a legally valid claim. The court takes all alleged facts as true and asks whether the claim is plausible on its face.

Defendants made three arguments for dismissal under Rule 12(b)(6):

Argument 1: No procedural claim alleged. Defendants argued that plaintiffs were simply complaining about slow action, not requesting additional procedural protections (such as a hearing), and therefore had not actually stated a procedural due process claim. The court rejected this, citing its earlier ruling in Rud v. Johnston (2023), where the same argument was rejected. The court found plaintiffs' allegations sufficient to raise a question about whether the state provided constitutionally adequate procedures surrounding the deprivation.

Argument 2: No deprivation occurred. Defendants advanced a novel "tenants-in-common" theory, arguing that all CAP order holders share a common property interest in the limited CPS facility space, and that a "first-in-time" waitlist is a lawful way to allocate that shared interest—just as creditors with competing claims against a debtor are paid in the order their claims were received. The court rejected this theory at the motion to dismiss stage. Drawing again from Rud (2025), the court emphasized that the right at stake is not just the right to transfer, but the right to transfer within a reasonable time—and that MSOP patients, unlike money-judgment creditors, cannot recover the time lost due to delay. The court declined to rule as a matter of law that the waitlist mechanism satisfied the "reasonable time" requirement.

Argument 3: Sufficient post-deprivation process exists. Defendants argued that even if plaintiffs were deprived of a protected interest, they have adequate remedies available. Defendants conceded that several of their arguments on this point had already been rejected in Rud. They raised one new theory in their reply brief: that plaintiffs could challenge their waitlist position under Minn. Stat. § 13.04, subd. 4, a state data-accuracy law allowing individuals to contest the accuracy or completeness of government-held data about themselves. The court noted it generally does not address arguments first raised in a reply brief, but addressed this one because it was discussed at the hearing. The court rejected the argument, finding that § 13.04 only allows individuals to correct clerical or administrative errors in their waitlist placement—it does not constitute a meaningful "opportunity to be heard" on the deprivation of their liberty and property interests, as required by the Mathews v. Eldridge balancing test (the standard federal courts use to assess what process is constitutionally required).

Rule 12(b)(7) — Failure to Join Necessary Parties

A Rule 12(b)(7) motion argues that the case must be dismissed because persons who are required to be part of the lawsuit ("necessary parties" under Rule 19) are absent. Defendants argued that because all CAP transfer order holders share the same property interest as tenants in common, every other order holder must be joined as a party, or the court cannot grant complete relief.

The court rejected this motion for two independent reasons. First, dismissal under Rule 12(b)(7) is only appropriate if necessary absent parties cannot feasibly be joined—a question the court had not yet reached, making dismissal premature. Second, and more fundamentally, the court concluded that other transfer order holders are not necessary parties at all. Plaintiffs are not asking the court to move them higher on the waitlist (which might harm others' positions); they are seeking additional procedural protections before being denied their right to timely transfer. Providing more process to the plaintiffs would not harm the interests of other CAP order holders, so their presence is not required under Rule 19.

Eleventh Amendment Bar on State Constitutional Claim

The Eleventh Amendment to the U.S. Constitution generally prohibits federal courts from ordering state officials to comply with state law. This principle, established in Pennhurst State School & Hospital v. Halderman (1984), reflects federalism concerns about federal courts intruding into state governance. Because plaintiffs sought an injunction against state officials for violating the Minnesota Constitution—a state law—the court held that the Eleventh Amendment bars this relief. The court granted the motion to dismiss Count I of the complaint to the extent it rests on the Minnesota Constitution, and expressly dismissed that claim with prejudice (meaning it cannot be refiled in federal court).

Ruling

The court granted the motion to dismiss in part and denied it in part: - Plaintiffs' procedural due process claim under the Minnesota Constitution (Count I) is dismissed with prejudice. - Defendants' motion to dismiss is denied as to the remainder of Count I—the federal procedural due process claim under the U.S. Constitution proceeds.