Graham v. Schnell
Alonzo J. Graham v. Paul Schnell, Commissioner of Corrections; Amy Longworthy; Hai Malon; Kenneth Peterson; Erik Rasmussen; Ashlee Berts; Jessie Pugh; Adam Booth; Nate Bartz; Stephen Craane; Thanh Weeks; Lisa Stenseth; Justin Jensen; Stephanie Huppert; Buchanan; Heather Sletten; J. Barnes; Olsen; Jacquelyn Chard; Watrin; Katherine Sitzman; Binger; Victor Wanchena; Racheal Orvis; Brandon Mariakis; Brandon Tatum; Bernadette Kingsbury; Becky Gross; Thielein; Linzy Meyer; Daryl Goebel; Jonathan Peterson; Joshua Fike; Sgt. Kunze; Lt. Bradly Steele; R. Erdman; and Sgt J. Hayes, in their official and individual capacities.
- Jerry Blackwell
- 0:25-cv-04798
- U.S. District Court · District of Minnesota
- 5
In Graham v. Schnell, Judge Blackwell dismissed Graham’s amended complaint without prejudice for failing to clearly identify claims and defendants, and denied several motions.
Alonzo J. Graham’s action was dismissed without prejudice, his listed motions were denied, and he remains responsible for the unpaid $320 filing-fee balance. The 37 named defendants were not required to defend the amended complaint because the case was dismissed at the pleading stage.
What happened
In Alonzo J. Graham v. Paul Schnell, Commissioner of Corrections, Graham objected to a magistrate judge’s recommendation that his amended complaint be dismissed without prejudice. The complaint involved 37 defendants and, as the court understood it, asserted retaliation and equal-protection claims.
The court concluded that the complaint did not give each defendant fair notice of the claims and facts directed against that defendant. Graham’s statements that the events were connected, that the defendants were jointly liable, and that discovery would establish the connections did not satisfy the requirement that he identify each defendant’s personal involvement. The court also said the dismissal was based on this pleading problem, not solely on misjoinder of parties.
Judge Blackwell overruled Graham’s objections, accepted the magistrate judge’s recommendation as consistent with the order, and dismissed the action without prejudice under Rule 8(a)(2). The court also denied Graham’s application to proceed without paying the full filing fee at the outset, motions for a hearing, appointed counsel, declaratory and emergency relief, and free copies. Graham was ordered to pay the unpaid $320 filing fee balance under the statutory payment procedure.
The detailed version
- Graham v. Schnell · No. 0:25-cv-04798
- Jerry W. Blackwell
- Sept. 22, 2026
Background
Alonzo J. Graham, representing himself, objected to United States Magistrate Judge Dulce J. Foster’s July 17, 2026 Report and Recommendation. The recommendation was that Graham’s amended complaint be dismissed without prejudice. The case named 37 defendants in their official and individual capacities.
The district court said it would review specific objections to the recommendation independently and review nonspecific objections for obvious legal or factual error. Because Graham represented himself, the court interpreted his objections liberally. The court reviewed Graham’s objections independently and found that they identified no legal or factual error requiring rejection of the recommendation.
Pleading Deficiencies
Federal Rule of Civil Procedure 8(a)(2) requires a complaint to provide a short and plain statement showing that the plaintiff is entitled to relief and giving defendants fair notice of the claims and their factual grounds. The court explained that this requirement applies with particular force in prisoner civil-rights cases involving many defendants.
Even interpreting the amended complaint liberally as asserting retaliation and equal-protection claims, the court found that it did not identify which claims were asserted against which defendants or the factual basis for each claim. Graham argued that every event was connected through retaliation for filing grievances, that discovery would prove the connections, and that naming the defendants jointly and severally eliminated the need to identify each defendant’s responsibility.
The court rejected those arguments. A plaintiff must plead each defendant’s personal involvement, and discovery is not the stage at which a plaintiff first identifies which defendant allegedly committed which constitutional violation. The court also stated that Graham had previously been warned that he could not leave it to the defendants or the court to determine which claims applied to which defendants.
The court said a continuing retaliatory campaign was not necessarily legally impossible. The problem was that the amended complaint largely stated that the events were connected without alleging facts tying the actors and incidents together. The court further explained that the recommended dismissal did not rest solely on improper joinder of parties; the central problem was the failure to satisfy Rule 8(a)(2).
Disposition
Judge Jerry W. Blackwell overruled Graham’s objections and accepted the magistrate judge’s Report and Recommendation to the extent consistent with the order. The court dismissed the matter without prejudice under Rule 8(a)(2).
The court separately denied Graham’s application to proceed without paying the full filing fee at the outset, motion for a hearing, motion for appointment of counsel, motion for declaratory and emergency relief, and motion for free copies. The court ordered Graham to pay the unpaid $320 balance of the statutory filing fee through the payment procedure required by 28 U.S.C. § 1915(b)(2), and directed the clerk to notify the authorities at the institution where Graham was confined.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.