Meyer v. Stacken
- Ann Montgomery
- 0:17-cv-01761
- U.S. District Court · District of Minnesota
- 3
Meyer v. Stacken: Judge Montgomery overruled defendants’ objection and adopted a recommendation partly granting and partly denying their motion to dismiss Meyer’s visitation claims.
Adam L. Meyer’s claims against the MSOP defendants: several claims were dismissed, while his official-capacity claims for prospective injunctive relief under the First Amendment and procedural Due Process Clause continued.
What happened
Adam L. Meyer, who is civilly committed to the Minnesota Sex Offender Program, sued four MSOP employees after his minor niece was denied visitation. He claimed the denial violated his First Amendment association rights and his procedural due process rights.
The defendants argued that Meyer had no association right to visitation with his niece and that the denial was reasonably related to therapeutic and institutional interests. They also argued that Meyer received sufficient notice and an opportunity to challenge the visitation decision. The court said the existing record was not developed enough to resolve those issues at the dismissal stage.
Judge Ann D. Montgomery overruled the defendants’ objection and adopted the magistrate judge’s recommendation. The recommendation granted in part and denied in part the motion to dismiss: it dismissed several categories of claims but allowed Meyer’s official-capacity claims for prospective injunctive relief under the First Amendment and procedural Due Process Clause to continue.
The detailed version
- Meyer v. Stacken · No. 0:17-cv-01761
- Ann Montgomery
- Sept. 25, 2019
Background
Adam L. Meyer is civilly committed to the Minnesota Sex Offender Program (MSOP). He requested visitation with relatives, including minor nieces and nephews. His minor niece applied for visitation, but MSOP denied the request. Meyer alleged that his treatment team and MSOP administrators told him visitation was inappropriate because of his treatment history. He filed suit against Nancy Stacken, Peter Puffer, Bruce Beaman, and Jannine Hebert in their individual and official capacities.
Meyer claimed that the denial violated his First Amendment right of association and his rights under the Due Process Clause. The defendants filed a motion to dismiss. Magistrate Judge Katherine M. Menendez recommended granting the motion in part and denying it in part.
Claims Recommended for Dismissal
The recommendation granted the motion to dismiss as to Meyer’s official-capacity claims for damages, all claims against Hebert and Puffer, Meyer’s substantive due process claims, and all claims against the defendants in their individual capacities.
Claims Allowed to Continue
The recommendation denied the motion to dismiss as to Meyer’s official-capacity claims for prospective injunctive relief under the First Amendment and the procedural Due Process Clause. Prospective injunctive relief is a court order directed at future conduct rather than an award of past damages.
The defendants objected to allowing those claims to proceed. They argued that a civilly committed sex offender in a secure treatment facility has no First Amendment association right to visitation with his niece. They also argued that, even if such a right exists, the visitation denial was reasonably related to legitimate therapeutic and institutional interests. Regarding procedural due process, they argued that Meyer had received notice and a fair opportunity to respond to the reasons for the denial.
Court’s Analysis
After reviewing the challenged portions of the recommendation independently, the court agreed that dismissing Meyer’s entire lawsuit at that stage was premature. The court noted that civil detainees are entitled to more considerate treatment and conditions of confinement than prisoners. Taking Meyer’s allegations as true, the court found that his status as a civil detainee and those allegations were sufficient to establish a cause of action at the pleading stage.
The court stated that the record had not been developed enough to determine whether the visitation denial was reasonably related to legitimate therapeutic and institutional interests. It also concluded that the record was insufficient to determine whether Meyer received the process to which he was constitutionally entitled.
Disposition
Judge Ann D. Montgomery overruled the defendants’ objection and adopted Magistrate Judge Menendez’s Report and Recommendation. The court therefore left in place the recommendation’s grant in part and denial in part of the defendants’ motion to dismiss. The First Amendment and procedural due process official-capacity claims seeking prospective injunctive relief survived the motion to dismiss; the other categories of claims identified in the recommendation were dismissed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.