Munt v. Schnell
- Donovan Frank
- 0:18-cv-03390
- U.S. District Court · District of Minnesota
- 4
In Munt v. Schnell, Judge Frank overruled objections, adopted recommendations, and dismissed claims against Minnesota and United States Courts without prejudice.
Joel Munt’s claims against the Minnesota Courts and United States Courts were dismissed without prejudice; Paul Schnell was substituted for Tom Roy as a defendant.
What happened
In Munt v. Schnell, Joel Munt, who represented himself, objected to a recommendation that his claims against the Minnesota Courts and United States Courts be dismissed under a federal prisoner-screening law.
Munt argued that the constitutional protection for states did not prevent him from suing Minnesota Courts because he was a Minnesota citizen. He also argued that the dismissal unfairly burdened a person representing himself. The court rejected those arguments and explained that states generally cannot be sued in federal court without consent, while federal courts are protected from suit unless immunity has been waived.
Judge Donovan Frank overruled Munt’s objections and adopted the recommendation. The court dismissed Munt’s claims against the Minnesota Courts and United States Courts without prejudice and substituted Paul Schnell for Tom Roy as a defendant.
The detailed version
- Munt v. Schnell · No. 0:18-cv-03390
- Donovan Frank
- June 20, 2019
Background
Joel Munt, proceeding without a lawyer, sued several defendants, including the Minnesota Courts and the United States Courts. The matter came before the court on Munt’s objections to Magistrate Judge Elizabeth Cowan Wright’s April 1, 2019 Report and Recommendation.
The recommendation advised dismissing Munt’s claims against the Minnesota Courts and the United States Courts under 28 U.S.C. § 1915A, which requires screening of certain prisoner complaints. It also recommended dismissing those claims without prejudice, meaning the dismissal did not bar refiling the claims.
Objections and Legal Reasoning
The recommendation concluded that the Minnesota Courts, as state entities, were protected from Munt’s claims by state immunity under the Eleventh Amendment. It also concluded that the court lacked subject-matter jurisdiction—the legal power to hear the claims—against the United States Courts. The recommendation further explained that federal agencies are generally protected by sovereign immunity unless the federal government has waived that protection, and that the relevant waiver did not apply to the United States Courts.
Munt argued that the Eleventh Amendment’s text did not bar a state from being sued by its own citizens. The court agreed that the text alone did not say that, but explained that the Supreme Court has held that an unconsenting state generally is immune from suits in federal court brought by its own citizens or citizens of another state. Munt also argued that the Fourteenth Amendment removed that immunity, but the court found that any applicable exceptions did not apply. The court acknowledged Munt’s concern that it was difficult for a person representing himself to know which defendants could properly be sued.
Ruling
Judge Donovan W. Frank overruled Munt’s objections and adopted Magistrate Judge Wright’s Report and Recommendation. Under 28 U.S.C. § 1915A, the court dismissed without prejudice the claims against the Minnesota Courts and dismissed without prejudice the claims against the United States Courts. The court also substituted Paul Schnell, Commissioner of Corrections, for Tom Roy as a defendant under Federal Rule of Civil Procedure 25(d).
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.