Jackson v. Dayton

Background

Tony Dejuan Jackson brought this civil-rights action under 42 U.S.C. § 1983 based on alleged mistreatment and overcrowding in prisons operated by the State of Minnesota. His 163-page amended complaint named 52 defendants, including state government officials and entities, corporate entities, and non-governmental persons.

The amended complaint asserted five categories of alleged violations: unconstitutional conditions of confinement; retaliation and mail tampering; unfair wage practices; hate crimes, harassment, and false imprisonment; and denial of Internet access. Jackson sought injunctive and declaratory relief, $3.5 billion in compensatory damages, and punitive damages. He also filed motions seeking injunctive and other relief and later filed three motions for permission to amend his complaint again.

Multiple defendants moved to dismiss. United States Magistrate Judge Tony N. Leung recommended granting those motions, denying Jackson’s other motions as moot, and dismissing the amended complaint with prejudice. Jackson objected to the recommendation.

Analysis

The district court reviewed Jackson’s objections independently. Federal Rule of Civil Procedure 8 requires a complaint to provide a short and plain statement showing that the plaintiff is entitled to relief. The court explained that a complaint must include enough facts to make a claim for relief plausible and must give each defendant fair notice of what that defendant allegedly did.

The court concluded that Jackson’s amended complaint did not satisfy that requirement. It repeated general allegations about his confinement conditions at least 14 times, cited various constitutional and statutory provisions without clearly connecting them to particular defendants, and failed to attribute specific allegations to 31 of the 52 defendants. As a result, the defendants would have had to speculate about what role each allegedly played.

The court recognized that Jackson was representing himself and therefore received some leniency in applying pleading standards. It nevertheless held that the defects made the entire amended complaint inadequate. The court stated that Jackson’s objections did not correct those defects and therefore did not address the recommendation’s alternative analyses of his claims.

The court also upheld dismissal with prejudice. It relied on Jackson’s repeated failure, despite prior notice, to correct deficiencies in his filings; his choice to submit longer and more convoluted pleadings instead; and the court’s statement that this was his fourth attempt to plead the merits of this specific cause of action. The opinion also noted that Jackson was already restricted under the Prison Litigation Reform Act from pursuing certain federal claims because of his history of claims that failed to state a basis for relief.

Order and effect

The court overruled Jackson’s objections and adopted the April 2, 2018 report and recommendation. It granted the defendants’ motions to dismiss and dismissed Jackson’s amended complaint with prejudice. It denied as moot Jackson’s motions for other relief, motions for injunctive relief, and motions to amend the complaint. Judge Wilhelmina M. Wright directed that judgment be entered accordingly.