Jones v. Raden

Background

Michael K. Jones filed an amended complaint asserting claims under 42 U.S.C. § 1983. The defendants included Daniel Raden, Tom Roy, Commissioner of Corrections, and Joe Hagerty, Sheriff of Wright County. The opinion explains that Paul Schnell replaced Roy as Commissioner of Corrections for claims against Roy in his official capacity, while Roy remained a defendant in his individual capacity. Sean Deringer replaced Hagerty as Sheriff of Wright County for claims against Hagerty in his official capacity, while Hagerty remained a defendant in his individual capacity.

A United States magistrate judge recommended granting the motion to dismiss filed by Raden, Roy, and Schnell. Jones did not file timely objections. The court therefore reviewed the recommendation for clear error, meaning it checked the record for an obvious mistake rather than conducting a full review.

Court’s analysis

The district court found no clear error in the recommendation’s conclusions that Jones’s § 1983 claims against Raden, Roy, and Schnell should be dismissed for lack of subject-matter jurisdiction and for failure to state a claim on which relief could be granted. The court also found no clear error in the recommendation that Jones’s claims against Hagerty and Deringer should be dismissed because Jones failed to serve them with the complaint and summons. Finally, the court found no clear error in the recommendation that it decline to exercise supplemental jurisdiction over Jones’s state-law claims. Supplemental jurisdiction is a court’s authority to hear related state-law claims alongside federal claims.

Disposition

Judge Wilhelmina M. Wright adopted the July 24, 2019 Report and Recommendation. The court granted the motion to dismiss filed by Raden, Roy, and Schnell. It dismissed Jones’s amended complaint without prejudice and directed that judgment be entered.