Burdunice v. Mjanger

Background

Plaintiff Lannon Lavar Burdunice is a prisoner incarcerated at the Minnesota Correctional Facility in Rush City following a state court conviction for second-degree intentional murder and unlawful possession of a firearm. He filed this lawsuit under 42 U.S.C. § 1983 — the federal statute that allows individuals to sue state or local officials for civil-rights violations — against four defendants: Siv Mjanger (a Washington County District Court judge), Teresa Underwood (a court administrator), Paul Schnell (Commissioner of the Minnesota Department of Corrections), and William Bolin (Warden at MCF-Stillwater). Burdunice alleged violations of his constitutional rights and sought damages, injunctive relief (specifically, an order compelling a new hearing), and declaratory relief (a declaration that defendants violated the Fourteenth Amendment).

Magistrate Judge Dulce J. Foster issued a Report and Recommendation (R&R) on December 19, 2025, recommending dismissal without prejudice on the ground that the complaint failed to state any claim upon which relief could be granted. Burdunice timely filed five objections. Because Burdunice is proceeding pro se (without a lawyer), the court applied a liberal construction standard to his filings.

Standard of Review

For dispositive matters, the district court reviews properly objected-to portions of an R&R de novo (independently, without deference to the magistrate). Objections that merely repeat arguments already made to the magistrate judge are reviewed only for clear error. The court noted that while pro se filings are held to a less stringent standard, pro se litigants are still required to comply with substantive and procedural law.

Analysis of Burdunice's Five Objections

Objection 1: Immunity

Burdunice argued the R&R wrongly extended immunity to block all forms of relief. The court disagreed on all three forms of relief:

- Damages against Judge Mjanger and Underwood: The R&R correctly found these claims barred by judicial immunity (protecting judges from personal liability for judicial acts) and quasi-judicial immunity (protecting court administrators performing functions integral to the judicial process).

- Injunctive relief against Judge Mjanger: Barred directly by 42 U.S.C. § 1983's own terms.

- Injunctive relief against the remaining defendants: Barred by the Rooker-Feldman doctrine, which prohibits federal district courts from effectively reviewing and overturning state court decisions. Because Burdunice's requested injunction (compelling a new hearing) would require the federal court to disturb a state court judgment, this doctrine applied.

- Declaratory relief: The Eighth Circuit has recognized that § 1983 does not automatically bar declaratory relief against judges, but the Eleventh Amendment bars retrospective declaratory relief — that is, a federal court cannot declare that state officials violated federal law in the past. Because Burdunice sought exactly that (a declaration that defendants' past actions violated the Fourteenth Amendment), this claim was also barred.

Objection 2: Judicial Discretion

Burdunice argued Judge Mjanger had no discretion because a hearing was required as a matter of law. The court rejected this as an attempt to relitigate the state court judge's legal conclusions. Under § 1983, a judge is immune from liability unless the challenged action was not taken in the judge's judicial capacity or the judge acted in the complete absence of all jurisdiction. The court found no evidence that Judge Mjanger acted in the absence of all jurisdiction, and mere disagreement with a judge's decisions does not state a cognizable (legally recognized) claim.

Objection 3: Premature Factual Resolution

Burdunice argued the R&R improperly weighed evidence, credited state court reasoning, and drew inferences against him at the screening stage — before defendants even answered. The court rejected this, finding the magistrate judge properly reviewed the complaint's allegations under 28 U.S.C. § 1915A (the statute requiring courts to screen prisoner complaints and dismiss those that fail to state a claim) and correctly concluded that none of the allegations supported a plausible claim for relief.

Objections 4 and 5: Policy-Based Arguments

Burdunice argued that defendants Bolin and Schnell had no legitimate interest in preserving his conviction, and that adopting the R&R would harm future litigants and undermine the judiciary. The court characterized these as policy-based objections that raised no specific challenge to the magistrate judge's legal reasoning, and rejected them. The court also expressly rejected the suggestion that dismissal without prejudice would harm future litigants or undermine the judiciary.

Disposition

The court overruled all five of Burdunice's objections, adopted Magistrate Judge Foster's R&R, and dismissed the complaint without prejudice. The court also denied as moot Burdunice's motion for entry of default.