Dalton v. Sandstone FCI
- Patrick Schiltz
- 0:20-cv-02231
- U.S. District Court · District of Minnesota
- 4
In Dalton v. Sandstone Federal Correctional Institute, Judge Menendez granted Dalton more time to submit financial information and any amended complaint.
Brandon Patrick Dalton, who received more time to provide financial information and any amended complaint; the case’s filing process was also affected.
What happened
In Dalton v. Sandstone Federal Correctional Institute, Brandon Patrick Dalton asked for more time to provide financial information needed for his application to proceed without paying the filing fee upfront and to prepare an amended complaint. He said quarantine and COVID-19 complications had delayed him.
The court granted his request and set March 20, 2021, as the deadline for both the financial information and any amended complaint. The court also directed the clerk to send him a long-form application for proceeding without paying the full filing fee upfront.
Judge Katherine Menendez explained that Dalton needed to provide six months of prison-account information and, if he amended his complaint, identify each individual official involved, what that person allegedly did, and when it happened. The order did not decide whether Dalton’s underlying claims were valid.
The detailed version
- Dalton v. Sandstone FCI · No. 0:20-cv-02231
- Patrick Schiltz
- Feb. 1, 2021
Background
Brandon Patrick Dalton filed a complaint and an application to proceed without paying the full filing fee upfront. The court previously explained that it could not calculate the initial partial filing fee because Dalton had not provided information about deposits to and the balance of his prison trust account for the six months before he filed the complaint.
The court also identified a problem with the complaint. Dalton named only Sandstone Federal Correctional Institute as the defendant, although his allegations concerned prison officials who were allegedly deliberately indifferent to his medical needs. The court advised him that he should identify the individual officials involved and explain what each person did.
Dalton requested several extensions. In a December 16, 2020 letter that he described as an amended complaint, he listed Mr. Bennett, Ms. Frye, M. Olson, M. Fuayah, and A. Balut, but he did not explain what each person allegedly did or when the conduct occurred. In a January 4, 2021 letter, Dalton requested another extension and stated that quarantine conditions and his contracting COVID-19 had delayed him.
Court’s reasoning
The court recognized that the COVID-19 pandemic could cause delays for unrepresented prisoners but stated that Dalton still had to provide the trust-account information needed to calculate his initial partial filing fee and address his pending application to proceed without paying the full filing fee upfront.
The court also explained that any amended complaint should be a new document titled “Amended Complaint.” It should separately name each individual official Dalton wanted to sue and identify, preferably in numbered paragraphs, what each person allegedly did and when the person took the relevant actions.
Order
The court granted Dalton’s request for an extension. It ordered that his financial information and any amended complaint be submitted by March 20, 2021. It also directed the clerk’s office to send Dalton one copy of the long-form application to proceed without paying the full filing fee upfront.
This order addressed filing requirements, an application to proceed without paying the full filing fee upfront, and additional time. It did not decide the merits of Dalton’s underlying claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.