Jackson v. Schnell

Background

Petitioner Tony Dejuan Jackson, a Minnesota prisoner proceeding without counsel (pro se), filed a complaint alleging unlawful conditions of detention in violation of the Eighth Amendment (prohibiting cruel and unusual punishment) and the Fourteenth Amendment. He named as respondents Paul Schnell and Sofia Khan (both identified as Commissioner of the Minnesota Department of Corrections at different times), Governor Tim Walz, and several deputy, assistant commissioners, and wardens at MCF-Faribault and MCF-Stillwater, all in their individual and official capacities.

Jackson has an extensive filing history in the District of Minnesota and is subject to a prior court order restricting him from initiating new litigation in that district without first satisfying certain conditions. See Jackson v. Schnell, No. 23-CV-0366 (PJS/DTS), Doc. No. 16 (D. Minn. May 24, 2023).

Jackson's complaint was initially filed in Iowa but was transferred to the District of Minnesota under 28 U.S.C. § 1406(a) — a statute allowing transfer to a proper venue — because the named defendants and the alleged events were tied to Minnesota.

Procedural History

After the initial filing, Magistrate Judge Elizabeth Cowan Wright conducted a preliminary review under 28 U.S.C. § 1915(a), which governs in forma pauperis (IFP) applications (requests to proceed without paying court filing fees). Jackson was given an opportunity to amend his original complaint, which he did. Magistrate Judge Wright then reviewed the amended complaint and issued a Report and Recommendation (R&R) recommending: (1) dismissal of the amended complaint without prejudice for failure to comply with Federal Rules of Civil Procedure 8(a)(2) and 20(a)(2); (2) denial of the motion for a Temporary Restraining Order (TRO); (3) denial of the IFP application; and (4) requiring payment of the $350 mandatory filing fee.

Jackson objected to the R&R, arguing his amended complaint did satisfy the Federal Rules of Civil Procedure, and also alleged that judges within the District of Minnesota had retaliated against him for filing an IFP application. No appearances or responses were entered by any of the named respondents.

Legal Standards Applied

The court reviewed Jackson's objections to the R&R de novo — meaning independently and from scratch — as required by 28 U.S.C. § 636(b)(1) and Federal Rule of Civil Procedure 72(b). The court also applied a rule of liberal construction to the filings of self-represented (pro se) litigants, citing Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004).

The two key pleading rules at issue were: - Rule 8(a)(2): Requires a pleading to contain "a short and plain statement of the claim showing that the pleader is entitled to relief." The purpose is to give defendants fair notice of what claims are being brought. - Rule 20(a)(2): Governs joinder of defendants — that is, the ability to sue multiple defendants in a single lawsuit. It requires that all defendants be related by common questions of law and fact arising from the same transactions or occurrences.

Holdings and Rulings

The court overruled Jackson's objections and adopted the R&R in its entirety.

On the amended complaint, the court found it was not concise and contained no clear statement of specific claims. Instead, it presented a wide variety of unrelated allegations against distinct defendants spanning many different dates. The court cited a prior case involving the same plaintiff — Jackson v. Schnell, No. 23-CV-0366, 2023 WL 3630889 (D. Minn. Apr. 20, 2023) — in which a previous complaint had similarly been dismissed under Rule 20(a)(2) for collecting wide-ranging complaints and stitching them into one pleading without satisfying the same-transaction or common-question requirements.

The amended complaint was dismissed without prejudice, meaning Jackson is not permanently barred from refiling if he can cure the deficiencies identified.

The TRO motion was denied.

The IFP application (request to waive the filing fee) was denied.

Jackson was ordered to pay the unpaid balance of $350 — the statutory filing fee — as prescribed by 28 U.S.C. § 1915(b)(2), which governs fee payment by prisoners. The Clerk of Court was directed to notify the institution where Jackson is confined of this payment obligation.

Notes on Jackson's Retaliation Allegation

Jackson alleged in his objection that judges within the District of Minnesota had retaliated against him for filing an IFP application. The court did not separately address or analyze this allegation in its ruling; it overruled the objections and adopted the R&R without discussion of the retaliation claim.