Yang v. State of Minnesota

Background

Mang Yang filed a civil action against the State of Minnesota, Ramsey County, and Ramsey County Jail. He did not pay the filing fee when he filed the case. Instead, he applied for permission to proceed without prepaying the full fee.

Because Yang is a prisoner, the Prison Litigation Reform Act requires him to pay the statutory filing fee even if the court allows him to proceed without prepayment. The fee may be paid in installments. The court must initially assess 20 percent of the greater of the prisoner’s average monthly deposits or average monthly balance during the six months before filing.

Yang’s trust-account records showed average monthly deposits of $209.14 and an average monthly balance of $78.47. Because the deposits were higher, the court calculated the initial partial fee as 20 percent of $209.14, or $41.82.

Order

The court granted Yang’s application to proceed without prepaying the full filing fee. It ordered him to pay an initial partial filing fee of at least $41.82 within 20 days of the order. If he pursues the case, the remaining balance of the $350 statutory filing fee must be paid through later deductions from his trust account, regardless of whether he succeeds in the case.

The court did not dismiss the action in this order. Instead, it stated that if Yang failed to pay the initial partial fee, it would be recommended that the action be dismissed without prejudice for failure to prosecute.

Warnings About the Complaint

The court warned that Yang’s complaint might be factually or legally deficient as currently written. It said that Yang referred generally to county-jail correctional officers who allegedly assaulted him and failed to address his mental-health needs during intake, but had not specifically identified those individuals.

The court explained that Yang could potentially recover damages only by bringing claims against a defendant in an individual capacity, or could seek injunctive relief by identifying an individual acting in an official capacity. It also warned that the jail and the State of Minnesota might not be proper defendants for claims under the federal civil-rights statute, 42 U.S.C. § 1983. The court stated that Ramsey County could be liable only under limited circumstances involving a county policy or practice, not merely because its employees allegedly acted wrongfully.

What the Ruling Did Not Decide

The order did not decide whether Yang was assaulted, whether officials failed to address his mental-health needs, or whether any defendant violated his rights. It addressed the filing-fee application and warned about potential defects in the complaint.