Fields v. Henry
- Wilhelmina Wright
- 0:17-cv-02662
- U.S. District Court · District of Minnesota
- 10
In Fields v. Henry, Judge Menendez denied Fields’s request to add claims without prejudice and addressed expert and discovery requests.
Victor Donnell Fields and the prison-official defendants; the order also required the defendants to address Fields’s expert-related request.
What happened
Fields v. Henry involved Victor Donnell Fields’s lawsuit under 42 U.S.C. § 1983, claiming that Minnesota prison officials were deliberately indifferent to his serious medical needs. Fields later submitted allegations about disciplinary actions, segregation, and confiscated materials that he said were retaliation or racial discrimination.
The court denied Fields’s request to file a supplemental pleading without prejudice because he had not provided a proposed pleading clearly identifying the claims and defendants. The court allowed him to renew the request by filing a properly formatted proposed supplemental complaint. The court also required the defendants to respond to his request involving three medical professionals and declined to order production of requested statistical records because the discovery request was premature and Fields had not shown that he tried to resolve the dispute before seeking court intervention. Two other filings raised discovery disagreements but asked for no relief, so the court made no ruling on them.
Judge Katherine Menendez issued the order on November 16, 2018. The order addressed case-management and discovery matters and did not decide whether Fields’s underlying constitutional claims were valid.
The detailed version
- Fields v. Henry · No. 0:17-cv-02662
- Wilhelmina Wright
- Nov. 16, 2018
Background
Victor Donnell Fields, an inmate at the Minnesota Correctional Facility in Rush City, brought a claim under 42 U.S.C. § 1983 against prison officials. He alleged that the defendants violated his constitutional right to be free from cruel and unusual punishment by deliberately disregarding his serious medical needs. The order addressed several later filings made before trial.
Motion to Supplement the Pleading
Fields submitted a filing describing events that allegedly occurred after he filed his amended complaint. He asserted that prison officials submitted false disciplinary reports, placed him in administrative segregation in retaliation for this lawsuit, possibly discriminated against him because he is Black, coerced him into signing a waiver admitting rule violations, and confiscated his legal and personal logs. The court treated the filing as a motion for permission to serve a supplemental pleading under Federal Rule of Civil Procedure 15(d), which governs adding allegations about events occurring after an earlier pleading.
The court agreed that Fields had identified some possible supplemental claims but denied the motion without prejudice. The court concluded that it remained unclear which claims Fields sought to add and which defendants he intended to sue on each claim. The court instructed Fields that he could renew the request by December 14, 2018, if he filed a document titled “Proposed Supplemental Complaint,” with a proper caption, each defendant identified, and the supporting facts stated in separately numbered paragraphs. If he filed that document, the court would treat it as a renewed motion and the defendants would have until January 11, 2019, to respond.
Expert-Witness Request
Fields asked the court to have three identified medical professionals examine him and provide reports. The court found it unclear whether he intended to identify an expert he would retain, asked the court to appoint an expert, or sought to have those professionals conduct a medical examination under Rule 35. The defendants had not addressed the request. The court therefore ordered the defendants to file a memorandum by November 28, 2018, addressing the request.
Discovery Requests
Fields asked the court to order production of statistical records concerning racial information, mental-health-unit admissions, sex-offender treatment or programming, certain diagnoses or symptoms, and anticipated parole or release dates. The court treated this as a motion to compel discovery, meaning a request for a court order requiring production of information. The court declined to issue the requested order for two reasons: the record did not show that Fields had first requested the materials through the ordinary discovery process, and he had not shown that he attempted to resolve the dispute before seeking court intervention, as required for a motion to compel.
Fields also filed two documents disputing responses to discovery requests. Because neither document asked the court for specific relief, the court made no ruling on the issues raised in them.
Disposition and Effect
The court denied Fields’s motion for leave to file a supplemental pleading without prejudice. It required a response concerning the proposed medical examination and declined to order production of the requested statistical records. It made no ruling on the two discovery-dispute submissions that requested no relief. The order did not decide the merits of Fields’s underlying medical-needs claim or any proposed retaliation or discrimination claims.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.