Maddox III v. Sather

Background

Harry Maddox III filed a civil-rights complaint under 42 U.S.C. § 1983 concerning his detention at the Chisago County Jail. He alleged that an illness caused infections in both eyes and that jail officials and medical workers ignored or mistreated the condition, causing lasting harm. He asserted claims against the defendants in both their personal and official capacities. He sought monetary compensation from most defendants, injunctive relief against Judge Suzanne Bollman, and an order requiring the preservation of medical records.

Maddox applied to proceed without paying the usual filing fees. Magistrate Judge Hildy Bowbeer granted that request and recommended dismissing all official-capacity claims, dismissing personal-capacity claims against John Grey, Tracy Armistead, Sarah Johnson, Ebenezer Tope Adebara, Kathleen E. Karnowski, Judge Suzanne Bollman, and Jacob Devermeyer, and allowing personal-capacity claims against Josh Sather, Lucas Anderson, Richard Benson, Sandi Lehman, Matthew Meskan, Gunnar Erickson, and Michael Eichler to proceed. She also recommended denying the request to preserve medical records.

Maddox objected, focusing mainly on the official-capacity claims involving Sather, Lehman, and Meskan. He asserted that Sather had withheld his real name and that Lehman and Meskan knew about the alleged deception. The court noted that an exhibit referred to “Josh Cather,” but made no finding about whether the defendant known as Josh Sather was actually Josh Cather and continued using “Sather.”

Court’s analysis

Because Maddox was proceeding without paying filing fees, the court screened his complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). A claim may be dismissed at this stage if, assuming the pleaded facts are true, the complaint does not plausibly state a right to relief. The court also reviewed the portions of the recommendation that Maddox specifically challenged and read his self-represented filings liberally.

The court held that official-capacity claims for damages against an employee of the Minnesota Department of Corrections were barred by state immunity. It also held that Karnowski’s alleged handling of Maddox’s correspondence was within the discretionary scope of her position and consistent with the Minnesota Rules of Civil Procedure.

For the county-related official-capacity claims, the court explained that such claims require allegations tying the claimed constitutional violation to an official policy, practice, or decision. Maddox’s allegations described individual conduct, not a county policy or official pattern. His new allegations about Sather’s name likewise did not plausibly show an official policy or procedure, even if the alleged conduct occurred.

The court also adopted the recommendation to dismiss the specified personal-capacity claims. It agreed that the alleged failure by Grey and Armistead to address grievances did not itself state a constitutional violation; that the allegations against Johnson described conduct within her administrative responsibilities; that the allegations against Devermeyer did not amount to a legal violation; and that the allegations against Adebara did not plausibly show a violation of Maddox’s rights. The court also adopted the recommendation concerning Karnowski and Judge Bollman, including the conclusion that Judge Bollman was immune from damages claims and that the requested medical-furlough injunction was moot or not properly before the federal court under the circumstances described.

The court agreed that a separate injunction requiring preservation of medical records was unnecessary because the records were already subject to retention requirements and Maddox had not shown a credible need for a court order.

Disposition

The court overruled Maddox’s objection and affirmed and adopted Magistrate Judge Bowbeer’s Report and Recommendation. It dismissed without prejudice all claims against defendants in their official capacities as agents of the State of Minnesota or Chisago County. It dismissed without prejudice from the action John Grey, Tracy Armistead, Sarah Johnson, Ebenezer Tope Adebara, Kathleen E. Karnowski, Judge Suzanne Bollman, and Jacob Devermeyer. It denied the motion for a preliminary injunction. The personal-capacity claims against Sather, Anderson, Benson, Lehman, Meskan, Erickson, and Eichler were permitted to proceed as recommended.