Munt v. Schnell

Background

Joel Marvin Munt sued Paul Schnell, David Reishus, Sherlinda Wheeler, Jeff White, Jeanne Michels, Sue Farmer, and Glenn D. Lisowy, whom the opinion identifies as employees of the Minnesota Department of Corrections. Munt was incarcerated at the Minnesota Correctional Facility in Oak Park Heights when he began the case. His amended complaint asserted two retaliation claims under 42 U.S.C. § 1983, along with claims involving access to the courts, equal protection, and conspiracy. He sought declaratory, injunctive, compensatory, and punitive relief.

After Munt was transferred to another Minnesota correctional facility, the defendants moved to dismiss. Magistrate Judge Becky R. Thorson recommended granting the motion. Munt objected, and the defendants responded.

Court’s Analysis

The district court reviewed the parts of the report and recommendation to which Munt made specific objections independently, while reviewing the remaining portions for clear error. Because Munt was representing himself, the court read his objections liberally.

Retaliation. To state a retaliation claim, Munt had to plausibly allege that he exercised a constitutional right, that the defendants took disciplinary or other adverse action against him, and that his protected conduct motivated that action. The court concluded that Munt’s own allegations showed that the discipline was based on his violation of a facility rule limiting inmates’ Internet access, rather than on the exercise of a constitutional right. The court also found that his allegations about printing restrictions did not connect those restrictions to protected conduct and instead merely speculated that the restrictions were intended to hinder his court access.

Conspiracy. The court found that Munt’s conspiracy allegations were conclusory and did not provide specific facts showing an agreement, a “meeting of the minds,” or an act taken to advance a conspiracy. The court also concluded that his claim under 42 U.S.C. § 1985 failed because the defendants were employees and agents of the same government entity, and Munt did not allege that they acted outside their authority or for their own benefit. In addition, he did not allege the class-based, discriminatory conduct required for the relevant conspiracy theory.

Access to the courts. The court held that Munt did not allege facts showing that the defendants intended to restrict his access to the courts or that their conduct actually hindered his ability to litigate. His allegations concerned printing restrictions and a temporary loss of access to the law library and legal papers. The court concluded that his litigation activity could be considered in assessing whether he had actually been denied meaningful court access.

Equal protection. Munt challenged printing restrictions under a “class-of-one” theory, which requires a person to show intentional different treatment from similarly situated people without a rational basis. The court found that Munt did not provide specific facts showing that other inmates were similarly situated and intentionally treated less restrictively. It also found that he did not identify a specific injury caused by the restrictions.

The court did not reach the report and recommendation’s alternative grounds involving immunity, mootness, or the availability of punitive and injunctive relief because it dismissed all claims for failure to state a claim on which relief could be granted.

Disposition

Judge Wilhelmina M. Wright overruled Munt’s objections, adopted the June 22, 2020 report and recommendation, and granted the defendants’ motion to dismiss. The court ordered that the case be dismissed without prejudice and directed that judgment be entered accordingly.