Hatton v. Piper
- Wilhelmina Wright
- 0:16-cv-03895
- U.S. District Court · District of Minnesota
- 4
In Hatton v. Piper, Judge Wright dismissed some claims with prejudice and the rest without prejudice, granted a late-reply motion, and denied amendment.
The dismissal affected Russell John Hatton and Lloyd Robert Desjarlais’s claims against the defendants. Claims under the American Indian Religious Freedom Act and the Minnesota Constitution were dismissed with prejudice; the remaining claims were dismissed without prejudice.
What happened
Russell John Hatton and Lloyd Robert Desjarlais sued 25 defendants, alleging that restrictions at the Minnesota Sex Offender Program prevented them from joining communal Native American religious ceremonies. They brought statutory and constitutional claims.
The court dismissed the claims under the American Indian Religious Freedom Act and the Minnesota Constitution with prejudice because those laws did not provide a private way to sue. It dismissed the remaining claims without prejudice, including claims affected by jurisdictional problems or failure to state a claim. The court also granted the plaintiffs’ request to accept their late reply and denied their request to amend the complaint.
Judge Wilhelmina M. Wright adopted the magistrate judge’s recommendation as modified and entered judgment on February 28, 2019.
The detailed version
- Hatton v. Piper · No. 0:16-cv-03895
- Wilhelmina Wright
- Feb. 28, 2019
Background
Russell John Hatton and Lloyd Robert Desjarlais sued 25 defendants in their individual and official capacities. They alleged that, while placed in disciplinary “Restrictive Status” at the Minnesota Sex Offender Program, they were denied the opportunity to participate in communal Native American religious ceremonies. Their complaint asserted statutory and constitutional claims.
The defendants moved to dismiss for lack of subject-matter jurisdiction and failure to state a claim. The plaintiffs also moved to have the court accept a late reply and to amend their complaint. No party objected to United States Magistrate Judge Steven E. Rau’s January 23, 2019 Report and Recommendation. Without timely objections, the district court reviewed the recommendation for clear error.
Court’s analysis
The court found no clear error in the recommendation that it lacked subject-matter jurisdiction over the plaintiffs’ request for monetary damages from defendants sued in their official capacities and injunctive relief from defendants sued in their individual capacities.
The court also found that the plaintiffs failed to state a claim under the American Indian Religious Freedom Act, the Minnesota Constitution, the Religious Land Use and Institutionalized Persons Act, and the First, Fourth, and Fourteenth Amendments to the United States Constitution.
The court modified the recommendation concerning whether the dismissal should be with prejudice. It explained that dismissal with prejudice is an adjudication on the merits, while claims dismissed for lack of subject-matter jurisdiction must be dismissed without prejudice. The court concluded that only the claims under the American Indian Religious Freedom Act and the Minnesota Constitution were fatally flawed because those laws did not provide a private cause of action.
Disposition
The court adopted the Report and Recommendation as modified. It granted the defendants’ motion to dismiss. The claims under the American Indian Religious Freedom Act and the Minnesota Constitution were dismissed with prejudice. The remaining claims were dismissed without prejudice.
The court granted the plaintiffs’ motion to accept their late reply and denied their motion to amend their complaint. The court directed that judgment be entered.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.