Hazley v. State of MN

Background

Hazley was incarcerated at the Minnesota Correctional Facility in Moose Lake when the Minnesota Court of Appeals determined that his sentence was unauthorized and sent his criminal case back to the district court for further proceedings. After the remand, the district court set bail. Hazley alleged that he tried to use money in his inmate account to post bail and obtain release, but officials prevented him from accessing or transferring the funds.

Hazley sued Tom Roy, Becky Dooley, and Kristi Cisar under 42 U.S.C. § 1983, alleging that they violated his Fourteenth Amendment due-process rights by contributing to his wrongful, prolonged incarceration. He also asserted a Minnesota state-law false-imprisonment claim. In his third amended complaint, Hazley identified Dooley, Cisar, and Roy as defendants sued in their individual capacities.

The court noted that Hazley’s claims against Roy were not properly included in the third amended complaint because an earlier order had dismissed official-capacity claims against Roy and did not permit Hazley to add individual-capacity claims against him. The magistrate judge therefore recommended dismissing the reasserted claims against Roy. The recommendation also concluded that Hazley adequately alleged claims against Dooley and Cisar.

Defendants’ objections

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. They argued that Hazley had no constitutional right to access his inmate account and that Dooley and Cisar were entitled to qualified immunity. Qualified immunity can protect government officials sued individually unless the complaint alleges a violation of a constitutional or statutory right that was clearly established when the alleged conduct occurred.

The court rejected the defendants’ characterization of Hazley’s claim as merely a claim for access to property. Reading Hazley’s pro se complaint liberally, the court determined that he was alleging a liberty interest in being free from detention after bail had been set, not only a property interest in accessing money. Hazley alleged that officials did not send the $800 bail to the Hennepin County Criminal Court, did not stop payment on the check, and did not return the funds to his forwarding address, preventing him from posting bail.

The court also agreed with the magistrate judge that the asserted liberty interest was clearly established for purposes of the motion to dismiss. It reasoned that several federal appellate decisions recognized a liberty interest in being free from detention once bail had been set and the required funds were available. The court concluded that a reasonable official at the Moose Lake facility would understand that restricting access to Hazley’s funds could prevent his release on bail, even though another facility would have carried out the actual release.

The court further agreed that Hazley adequately alleged deliberate indifference by Dooley and Cisar. Because the federal § 1983 claims against them survived the motion to dismiss, the court did not address whether it continued to have supplemental jurisdiction over the related state false-imprisonment claims.

Ruling

Judge Eric C. Tostrud overruled the defendants’ objections and accepted the magistrate judge’s Report and Recommendation in full. The court granted in part and denied in part the defendants’ motion to dismiss. It granted the motion as it related to the claims against Tom Roy and denied it as it related to Becky Dooley and Kristi Cisar.

The court also denied Hazley’s motion to proceed in response to the defendants’ motion to dismiss as moot. It denied Hazley’s motion to respond to a September 21, 2018 letter because the proposed sur-reply was not authorized by the district’s local rules or by the court’s order.