Earley v. Schnell

Background

Nicholas Earley brought a civil-rights action against Paul Schnell, the Minnesota Commissioner of Corrections, in his official capacity; Edward Miles, the warden of the Minnesota Correctional Facility in St. Cloud, in his individual capacity; and two unidentified Minnesota Department of Corrections employees. Earley filed the action while incarcerated and was later placed on supervised release.

A supervised-release condition barred Earley from having direct or indirect contact with anyone the Minnesota Department of Corrections considered a victim. Under the department’s policy, Earley’s fiancée remained classified as a victim because she was named as a victim in a criminal complaint, even though the related domestic-assault charges were dismissed as part of Earley’s guilty-plea agreement on a first-degree driving-while-impaired charge. Because Earley’s fiancée was the mother and primary caregiver of his minor son, the condition also limited Earley’s ability to spend time with his son.

Earley alleged that the condition violated his First Amendment, Fourteenth Amendment, and Eighth Amendment rights to association. He sought declaratory and injunctive relief, damages, costs, and attorneys’ fees. Both sides moved for summary judgment; defendants also sought judgment on the pleadings, which uses the same legal standard as a motion to dismiss for failure to state a claim.

Ruling on Earley’s Claims About His Son

The court held that the condition’s effect on Earley’s relationship with his son was indirect. An indirect or incidental restriction on a constitutional right does not necessarily violate the First Amendment. The court therefore overruled Earley’s objection and rejected his constitutional claims concerning his son.

Substantive-Due-Process Claim

The court also rejected Earley’s objection to judgment for defendants on his substantive-due-process claim against Schnell. The court explained that a challenge to a state-imposed supervised-release condition requires proof that the condition violated a fundamental right and involved conscience-shocking conduct—meaning an extreme violation resulting from brutal and inhumane abuse of official power. The court held that the magistrate judge properly rejected Earley’s argument for applying strict scrutiny and overruled the objection.

First Amendment Claim Concerning Earley’s Fiancée

The parties did not dispute that Earley’s relationship with his fiancée was protected by the First Amendment right to freedom of association. The court held that the federal standard from Turner v. Safley, as modified for supervised release, was the proper standard rather than a Minnesota state-law standard or strict scrutiny.

Under the modified Turner test, the court considers whether the restriction is reasonably related to legitimate government interests. The magistrate judge had found a genuine dispute of material fact about whether Standard Condition 6 was rationally connected to the state’s goals and concluded that the record was not developed enough to evaluate other factors. The district court agreed and overruled both sides’ objections concerning this claim. The claim therefore remained unresolved on summary judgment.

Attorneys’ Fees

The court sustained Earley’s objection to granting defendants summary judgment on the attorneys’ fees connected to his remaining First Amendment claim against Schnell. The court explained that a plaintiff who succeeds in a civil-rights action under Section 1983 may be eligible for attorneys’ fees. Because Earley’s First Amendment claim survived, the court found no basis at this stage for granting defendants summary judgment on those fees.

Disposition

The court vacated its February 17, 2021 order, overruled defendants’ objections, sustained Earley’s objections in part and overruled them in part, and adopted the magistrate judge’s report and recommendation as modified.

The court denied Earley’s motion for summary judgment. It granted in part and denied in part defendants’ motion for summary judgment or judgment on the pleadings: the motion was denied as to Earley’s First Amendment claim against Schnell based on his relationship with his fiancée, including the related request for attorneys’ fees, and granted in all other respects.