Jackson v. State of MN
- John Tunheim
- 0:19-cv-00741
- U.S. District Court · District of Minnesota
- 5
In Jackson v. State of Minnesota, Judge Tunheim dismissed the action without prejudice, denied fee-waiver status, and denied the motions as moot.
Howard G. Jackson’s action was dismissed without prejudice. The State of Minnesota, unnamed state and federal agencies, and President Donald Trump were the defendants named in the action.
What happened
In Jackson v. State of Minnesota, Howard G. Jackson sued the State of Minnesota, unnamed state and federal agencies, and President Donald Trump, alleging constitutional violations and other matters. He did not connect specific claims to specific defendants.
Jackson asked to proceed without paying the filing fee and filed motions concerning reassignment, a hearing, and compelling proceedings. A magistrate judge recommended denying the fee-waiver request and dismissing the complaint because it did not state a claim, as well as denying the reassignment objection.
Judge Tunheim overruled Jackson’s objections, adopted the recommendation, dismissed the action without prejudice, denied the fee-waiver application, and denied the remaining motions as moot. The court found that the complaint lacked factual support and did not connect any defendant to any claim.
The detailed version
- Jackson v. State of MN · No. 0:19-cv-00741
- John Tunheim
- July 17, 2019
Background
Howard G. Jackson brought a civil action against the State of Minnesota, unnamed state and federal agencies, and President Donald Trump. He alleged violations of various constitutional rights and referred to gang stalking, true and false hate crimes involving an incident concerning Jussie Smollett in Chicago, defamation, and corruption. The opinion states that Jackson did not directly connect any claim to any named defendant.
Jackson applied to proceed without paying the filing fee. Magistrate Judge Becky R. Thorson found that he qualified financially but recommended denying the application and dismissing the complaint because it failed to state a claim on which relief could be granted. She also recommended denying Jackson’s objection to reassignment because he had not sufficiently alleged a conflict of interest or other basis for recusal.
Jackson later filed another motion for a hearing and a motion to compel. His filings objected to reassignment and referred to a hearing concerning summary judgment, evidence preservation, and a tort claim.
Court’s analysis
The court reviewed Jackson’s objections under the standards governing objections to a magistrate judge’s report and recommendation. It found that the objections were nonspecific and repetitive, so it reviewed them for clear error. The court stated that it would reach the same result even under the more searching standard that applies to specific objections.
The court applied the rule requiring dismissal of an action proceeding without payment of the filing fee when the complaint fails to state a claim. A complaint must provide enough factual material to make a requested legal remedy plausible rather than speculative. Although courts must read complaints filed without a lawyer generously, those complaints still must contain enough facts to support the asserted claims.
The court concluded that Jackson offered no factual support for his claims and did not connect any defendant to any claim. It therefore agreed with the magistrate judge that the complaint failed to state a claim.
Disposition
The court overruled Jackson’s objections and adopted the Report and Recommendation. It dismissed the action without prejudice under the statutory provision cited in the order, denied Jackson’s application to proceed without paying the filing fee, denied the April 3 motion for a hearing as moot, denied the April 19 motion for a hearing as moot, and denied the motion to compel as moot. Judge John R. Tunheim directed that judgment be entered.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.