Fields v. Berts

Background

Victor Fields, an inmate in the Minnesota state prison system who represented himself, brought claims under 42 U.S.C. § 1983 against state agencies and numerous state officials in their individual and official capacities. His core allegation was that defendants had conspired, and were conspiring, to have other inmates physically assault him and harm him in other ways.

The matter came before District Judge Eric C. Tostrud on Magistrate Judge Hildy Bowbeer’s order and report and recommendation. The report treated Fields’s Second Amended Complaint as the operative complaint, denied an implicit request to amend it, recommended dismissing some claims for lack of subject-matter jurisdiction, and recommended denying Fields’s motion for a temporary restraining order and preliminary injunction. Fields also filed a later motion titled “Urgent Emergency My Life Is In Danger By Prison Officials, Officers, Staffs, And Offenders.”

Request to Amend

After filing the Second Amended Complaint, Fields submitted several additional documents. The magistrate judge understood those filings as an implicit request to amend the complaint and denied the request because the filings did not comply with Federal Rule of Civil Procedure 15 and the District of Minnesota’s local rules.

Judge Tostrud overruled Fields’s objection and affirmed that denial. The local rules required a proposed amended pleading to be complete in itself and to show how it differed from the operative pleading. The court found that Fields’s filings did not meet that requirement and that combining the filings into an amended pleading would impose an unacceptable burden on the court and defendants.

Claims Dismissed During Screening

The court accepted the recommendation to dismiss without prejudice Fields’s claims against MCF–Rush City, the Minnesota Department of Corrections Office of Special Investigations, and the MCF–Rush City Crisis Intervention Team. The court held that the Eleventh Amendment barred the claims against those state entities and found nothing in the record showing that they had waived immunity or consented to suit.

The court also accepted the recommendation to dismiss without prejudice Fields’s damages claims against individual defendants in their official capacities. It explained that the Eleventh Amendment bars damages claims against state employees sued in their official capacities.

The remaining claims against individual defendants were allowed to proceed past the screening stage. The court stated that defendants were not precluded from later asserting another basis for dismissal. The order did not decide the merits of those remaining claims.

Requests for Emergency Relief

Fields’s original motion sought a temporary restraining order and preliminary injunction, including an order directing his transfer out of Minnesota and into another state’s prison system. A preliminary injunction is an extraordinary remedy, and the party seeking it must address four considerations: the likelihood of success on the merits, the threat of irreparable harm, the balance of harms, and the public interest.

Judge Tostrud denied the motion. Even setting aside procedural defects, the court found that Fields had not sufficiently addressed those considerations or provided enough factual or legal support. The court also noted that the record did not show that Fields had served defendants with the motion or provided the notice certification required for emergency relief, but it assumed without deciding that defendants were on notice after their counsel appeared.

Fields’s later emergency motion appeared to add allegations about conduct occurring after his earlier filings and sought a criminal investigation and continuing judicial supervision of defendants. To the extent it sought to amend the complaint, the court denied it for the same failure to comply with the local rules. To the extent it sought additional preliminary relief, the court denied it because Fields did not sufficiently address the required factors or provide adequate support.

Order

The court overruled Fields’s objections, accepted the report and recommendation, and affirmed the denial of his implicit motion to amend. It dismissed without prejudice the claims against MCF–Rush City, the Office of Special Investigations, and the Crisis Intervention Team, and dismissed without prejudice the damages claims against individual defendants in their official capacities. It denied both Fields’s motion for a temporary restraining order and preliminary injunction and his “Urgent Emergency My Life Is In Danger” motion. Judgment was entered only on the denial of the requests for preliminary injunctive relief.