Jackson v. Walz
- Joan Ericksen
- 0:19-cv-02612
- U.S. District Court · District of Minnesota
- 2
Jackson v. Walz: Judge Ericksen dismissed the complaint without prejudice after screening, finding generalized allegations failed to state a claim; related motions were denied as moot.
Tony Dejuan Jackson and the other prisoners for whom he filed the complaint; the complaint was dismissed without prejudice, and his listed motions were denied as moot.
What happened
Tony Dejuan Jackson filed a complaint on behalf of himself and other inmates against public officials, private individuals, public agencies, and private entities. A magistrate judge screened the complaint before service and recommended dismissal because it did not adequately state a claim for relief.
Jackson objected to that recommendation. He also asked the court to require Minnesota to limit prison populations and release prisoners to protect them from COVID-19.
Judge Joan N. Ericksen adopted the recommendation and dismissed the complaint without prejudice. The court denied Jackson’s COVID-19 motion and his other listed motions as moot because the case had been dismissed.
The detailed version
- Jackson v. Walz · No. 0:19-cv-02612
- Joan Ericksen
- Mar. 24, 2020
Background
Tony Dejuan Jackson filed a complaint on behalf of himself and other similarly situated inmates against public officials, private individuals, public agencies, and private entities. The opinion does not describe the specific underlying claims in detail.
A magistrate judge conducted the required pre-service screening of the complaint under 28 U.S.C. § 1915A. The magistrate judge recommended dismissal for failure to state a claim, meaning the allegations did not adequately show a legal basis for relief. The recommendation stated that the complaint did not satisfy the federal rule requiring a short and plain statement of the claim.
Court’s analysis
Jackson objected to the magistrate judge’s Report and Recommendation. The district court reviewed the recommendation and the objections independently. It concluded that the complaint and objections relied on generalized allegations and conclusory statements that did not state a claim for relief. The court therefore adopted the recommendation and accepted its proposed disposition.
Other motions and disposition
On March 19, 2020, Jackson moved for a temporary restraining order requiring Minnesota to impose prison-population limits and release prisoners to protect them from COVID-19. The court denied that motion as moot because it dismissed the case. The court also noted that the complaint did not mention the COVID-19 effects raised in the motion, so the case was not an appropriate vehicle for that request.
The order ruled as follows:
- Jackson’s complaint was dismissed without prejudice.
- His application to proceed without prepaying fees or costs was denied as moot.
- His motion for appointment of counsel was denied as moot.
- His motion to enjoin exhibits from previously filed civil cases was denied as moot.
- His motion concerning newly produced direct evidence was denied as moot.
- His motion requesting emergency preliminary-injunction orders was denied as moot.
The order entered judgment accordingly. This was a screening-based disposition rather than a decision resolving the underlying legal claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.