Miles v. Johnston

Background

Gordon Miles filed this action in March 2024. His first amended complaint included a First Amendment retaliation claim, a Fourteenth Amendment claim concerning alleged cruel and unusual punishment, and a Fourteenth Amendment due-process claim. In a prior ruling accepted by Judge Eric C. Tostrud, most of the amended complaint was dismissed. The remaining portion involved alleged attempts to place Miles in a double room or lock him in a room with another person and conduct concerning Unit 1-E.

The court’s October 29, 2025 scheduling order set February 21, 2026, as the deadline to amend the pleadings and add parties. Miles filed his motion to amend on February 12, 2026. His proposed second amended complaint removed dismissed claims and defendants, removed the Doe defendants, and added four proposed defendants: Dr. Mindy Siegert-Horgeshimer, Ann Linkert, Dr. Kathryn Schesso, and Scott Giannini. The proposed pleading alleged that these individuals were members of Miles’s treatment team and were involved in ending a single-room restriction or attempting to place him in a room with another person.

Parties’ Arguments

Miles argued that he learned the proposed defendants’ identities through discovery, that his motion was timely, and that the correct defendants should be included in the existing case. The defendants opposed amendment based on alleged undue delay and prejudice. They argued that the new allegations added little to the earlier allegations and that adding defendants could cause further delay because the new defendants might file motions to dismiss.

Court’s Analysis

Federal Rule of Civil Procedure 15 generally allows amendment when justice requires, although a court may deny amendment for undue delay, bad faith, futility, or unfair prejudice. The court found that Miles filed within the scheduling-order deadline. It also found no evidence that he delayed unreasonably, noting that discovery had begun only a few months earlier and that the defendants did not argue Miles knew the proposed defendants’ identities much earlier.

The court rejected the argument that the new allegations were too late because the allegations concerned conduct occurring in November 2024 and February 2025, rather than being filed long after that conduct. The court also rejected the argument that two proposed defendants could not have been treatment-team members at the relevant time, explaining that issue could not be decided on a motion to amend. The court acknowledged that adding defendants might lead to further motions, but found that the defendants had not shown resulting undue prejudice. It concluded that judicial efficiency favored addressing related events in one case rather than requiring a separate action.

Ruling and Case Status

The court granted Miles’s Motion for Leave to File Amended Complaint. Docket Entry 88-1 became the operative Second Amended Complaint. However, the court struck the portions of Claim II(C) concerning Defendant David Miles’s “Individual Treatment Plan” and “Individual Program Plan,” because those claims had previously been dismissed.

The court required Miles to submit a completed Marshal Service Form for each new defendant. If he does not return the forms within 30 days of the order, the court will recommend that the matter be dismissed without prejudice for failure to prosecute. The Clerk must seek waivers of service from the new defendants in their personal capacities, and the U.S. Marshals Service must serve them in their official capacities as agents of the State of Minnesota. The existing defendants Nancy Stacken, Courtney Menton, David Miles, and Kristen Sherlock must respond to the Second Amended Complaint. This order addressed amendment and service; it did not decide the merits of the surviving claim.