Keita v. Halverson

Background

Keita filed an amended complaint asserting an Eighth Amendment claim through the Fourteenth Amendment against Travis Binkley, Lisa Conners, and Kathryn Halverson in their individual capacities. He alleged that on August 5, 2024, Binkley ordered subordinates to place him in a restraint device after he refused to remove his hand from a book path and disobeyed orders. Keita alleged that Binkley denied him bathroom access and kept him restrained for four to five hours, contrary to Minnesota Department of Corrections policy. He claimed that the restraint caused him to urinate on himself, lose feeling in his legs, suffer back, neck, and spine pain, and experience nightmares.

Keita alleged that Conners and Halverson acted with deliberate indifference by denying his grievance about Binkley’s conduct. He sought declaratory relief, injunctive relief including medical care, and monetary damages. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which asks whether the complaint states a legally sufficient claim. Keita did not file a response.

Claims Against Conners and Halverson

The court concluded that the amended complaint did not allege facts showing that Conners or Halverson personally participated in placing or keeping Keita in the restraint. Their supervisory positions alone were insufficient to establish liability under 42 U.S.C. § 1983, which allows claims against state officials for violating federal rights. The court also concluded that rejecting Keita’s grievance after the incident could not have caused the earlier restraint and that Keita did not allege an injury resulting from the grievance rejection. The court therefore recommended that the motion to dismiss be granted without prejudice as to Conners and Halverson.

Claim Against Binkley

The court analyzed qualified immunity, a protection from personal damages liability unless an official violated a constitutional right that was clearly established at the time. The court determined that Keita had not identified controlling authority or a strong consensus of persuasive cases clearly establishing that Binkley’s conduct was unconstitutional in the particular circumstances alleged.

The court considered Keita’s allegations alongside grievances attached to his earlier complaint. Those grievances stated that Keita was restrained for periods described as two hours, over three hours, and over three hours, and that he had repeatedly resisted staff after being removed from the restraint. The court stated that violations of prison policy alone do not establish an Eighth Amendment violation. It concluded that restraining Keita for two to three hours after repeated failures to comply with orders was not completely without a disciplinary or safety-related justification. The court therefore recommended dismissing the individual-capacity claim against Binkley on qualified-immunity grounds.

Injunctive and Declaratory Relief

The court concluded that Keita’s release from Minnesota Department of Corrections custody on October 28, 2025, made his requests for prospective injunctive and declaratory relief moot because he was no longer subject to the alleged conduct at the facility. It recommended that those requests be denied as moot and that the related claim be dismissed without prejudice for lack of subject-matter jurisdiction.

Recommendation and Status

Judge Elizabeth Cowan Wright recommended that the defendants’ motion to dismiss be granted and that the amended complaint be dismissed without prejudice. The report and recommendation states that it is not an order or judgment of the district court and is not directly appealable to the Eighth Circuit. The opinion states that the parties may file written objections within the specified period, but it does not state whether the district judge later adopted the recommendation.