Williams v. Howard
- Katherine Menendez
- 0:20-cv-00439
- U.S. District Court · District of Minnesota
- 7
In Williams v. Howard, Judge Thorson denied defendants’ motion for a more definite statement, finding Williams’s claims understandable enough to answer.
The Olmstead County Defendants’ motion was denied, and Williams’s amended complaint was not required to be rewritten under Rule 12(e). The court did not decide whether Williams’s underlying constitutional claims were valid.
What happened
In Williams v. Howard, Terrence T. Williams, who represented himself, sued under a federal civil-rights law, alleging that several defendants violated his constitutional rights while he was in Minnesota Department of Corrections custody. The defendants asked the court to require him to rewrite his complaint with more detail.
The court said a complaint must be rewritten only when it is so unclear that the opposing party cannot reasonably respond. Although Williams’s amended complaint was lengthy and sometimes difficult to follow, the court found that it identified understandable allegations against particular defendants, including alleged sexual harassment, disciplinary actions, food problems, poor confinement conditions, inadequate medical care, interference with religious practice, and restricted access to legal resources.
The court denied the defendants’ motion for a more definite statement. Judge Becky R. Thorson explained that the ruling did not decide whether Williams’s factual or legal claims were valid; it only found that the defendants had enough notice to respond.
The detailed version
- Williams v. Howard · No. 0:20-cv-00439
- Katherine Menendez
- Jan. 19, 2021
Background
Terrence T. Williams, an inmate in the custody of the Minnesota Department of Corrections, brought claims under 42 U.S.C. § 1983, a federal law that permits claims for violations of constitutional rights by persons acting under state authority. Williams represented himself. The operative pleading was his amended complaint.
The Olmstead County Defendants—Brian Howard, Dave Adams, Macey Tezmer, Durand Ackman, Mark Anderson, Travis Pries, Madyson Erdelac, Sam Reps, Katlin Bain, and Brook Heim—filed a motion under Federal Rule of Civil Procedure 12(e) for a more definite statement. They argued that Williams’s narrative was too unclear to show which federal rights he believed each defendant had violated. They asked the court to require Williams to identify each defendant’s personal involvement, the dates and places involved, the specific acts or omissions alleged, and to use separately lettered paragraphs.
Legal Standard
Rule 12(e) permits a motion for a more definite statement when a pleading is so vague or ambiguous that the opposing party cannot reasonably prepare a response. The court explained that such motions are disfavored because federal pleading rules generally require notice of a claim rather than extensive detail, and because discovery can provide additional information. The question was whether the amended complaint was unintelligible, not whether it contained every detail the defendants wanted.
Because Williams represented himself, the court also applied the rule that self-represented pleadings must be read generously. The court said that a claim may be considered within the proper legal framework when the substance of the allegation can be understood even if it is not written in legal terms.
Court’s Analysis
The court found that Williams’s amended complaint was long and sometimes difficult to follow, but that it contained discernible allegations directed at identifiable defendants. The court gave several examples:
- Pries and Erdelac allegedly sexually harassed Williams. - Pries and Erdelac allegedly targeted him with disciplinary reports that led to an unjustified period in segregation. - Pries, Erdelac, Bain, and Heim allegedly mishandled and contaminated his food. - Howard, Ackman, Adams, and Tezmer allegedly denied grievances concerning his placement in segregation. - Pries, Erdelac, Ackman, Howard, Tezmer, Adams, and Anderson allegedly ignored complaints and grievances about living conditions in segregation and Williams’s medical needs. - Heim and Bain allegedly wrote false reports against Williams and disciplined him for practicing his religion. - Ackman allegedly restricted Williams’s access to legal resources to deny him access to the courts.
The court said these allegations could be understood as claims involving unconstitutional conditions of confinement and deliberate indifference to medical needs under the Eighth Amendment, violation of First Amendment religious-practice rights, and denial of access to the courts. The court noted that Williams could seek permission to file a second amended complaint if he intended to plead different claims.
Disposition
The court denied the Olmstead County Defendants’ Motion for More Definite Statement. It did not decide the merits of Williams’s factual or legal allegations and took no position on any other possible challenge to the amended complaint.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.