Munt v. Schnell

Background

Joel Munt, representing himself, sued Paul Schnell and other named defendants. The opinion identifies the defendants as including corrections officials and employees, the United States Courts, and the Minnesota Courts. Munt objected to Magistrate Judge Elizabeth Cowan Wright’s January 31, 2020 report and recommendation, which recommended granting the defendants’ motion to dismiss, denying Munt’s motions and requests, declining supplemental jurisdiction over his state-law claims, and dismissing his claims without prejudice.

The district court conducted a new review of the record and Munt’s objections. It found that Magistrate Judge Wright had addressed Munt’s claims and arguments and that her recommendations were factually and legally correct.

Claims and analysis

The opinion states that Munt brought claims involving retaliation, the constitutionality of certain Department of Corrections Offender Discipline Regulations, due process, equal protection, access to courts, and conspiracy under 42 U.S.C. §§ 1983, 1985, and 1986.

The court agreed that Munt’s claims for monetary relief against defendants in their official capacities were barred by state immunity under the Eleventh Amendment. It also agreed that his requests for retrospective injunctive relief did not connect the requested relief to an ongoing violation of federal law. The court further agreed with the recommendation that injunctive-relief claims against defendants in their individual capacities were barred.

The court held that Munt’s retaliation claim was inadequately pleaded because the challenged discipline and transfer were attributed to his disruptive conduct, security concerns, or rules violations to which he pleaded guilty, while his allegation concerning later discipline was conclusory. His challenges to the disciplinary regulations also failed. The court agreed that the restrictions on communication with a correctional officer had a rational connection to prison order and staff protection, and that Munt had not identified a practical alternative. It also agreed that the vagueness, overbreadth, and as-applied challenges were insufficient.

Munt’s due-process theories failed because he did not show a protected liberty interest in the challenged segregation placement, prisoners do not have a constitutional right to a particular prison job, the communication restriction did not appear to result from a lack of a hearing, and his substantive due-process allegations did not show conduct intended to injure him in an unjustifiable way. His equal-protection claim failed because he did not allege that similarly situated people were treated differently or that the defendants acted with intentional discrimination. His access-to-courts claim failed because he did not identify a nonfrivolous or meritorious legal claim that prison officials prevented him from pursuing; the opinion states that this also deprived him of standing for that claim.

The conspiracy claims failed because the § 1983 conspiracy claim depended on the failed retaliation and access-to-courts claims. The § 1985 claim also failed because the defendants were employees of the same governmental organization and because the other rights allegations failed. The § 1986 claim, which Munt raised in his response rather than in his complaint, failed because it had to be based on a valid § 1985 claim. The court also agreed that Munt had not adequately alleged personal involvement by several defendants in their individual capacities, and that the allegations did not support punitive damages. Because the constitutional claims failed, the defendants were entitled to qualified immunity, which protects government officials from liability unless they violated a clearly established statutory or constitutional right. The court declined to exercise supplemental jurisdiction over the state-law claims after dismissing the claims within its original jurisdiction.

Motions and disposition

The court overruled Munt’s objections and adopted Magistrate Judge Wright’s report and recommendation. It granted the defendants’ motion to dismiss. It denied Munt’s Request for a Stay and Sanctions, Request for a Gag Order, Motion to Certify Class, Request for Sanctions, Motion to Strike, and Request for Court Actions. The court’s discussion states that the class-certification motion was denied as moot and would also have been denied as premature, but the numbered order states simply that the motion was denied. The court dismissed Munt’s complaint without prejudice, meaning the order did not bar refiling. The opinion does not state that the court entered any separate disposition for the United States Courts or Minnesota Courts beyond the order’s treatment of the complaint and motions.