Linehan v. Attorney General's Office

Background

Dennis D. Linehan filed a civil-rights complaint under 42 U.S.C. § 1983 and an application to proceed without paying fees. He alleged that defendants engaged in wrongful conduct to ensure his indefinite civil commitment to the Minnesota Sex Offender Program. His allegations included claims that prosecutors misused evidence and withheld exculpatory evidence in his underlying criminal proceedings, and that defendants targeted him and created statutes or agency variances to guarantee his continued commitment.

The complaint appeared to assert seven claims under § 1983 and one claim under the False Claims Act. The § 1983 claims alleged violations involving due process, equal protection, double jeopardy, deliberate indifference, supervision, and failure to correct past violations. The False Claims Act claim alleged that defendants targeted him with the intent to confine him under false pretenses, including by withholding exculpatory evidence.

Report and Recommendation and Objections

Magistrate Judge Leo Brisbois recommended dismissal for failure to state a claim. He concluded that all of Linehan’s claims rested on the allegation that defendants’ conduct made his civil commitment unconstitutional, and that Heck v. Humphrey barred the claims.

Linehan objected. He argued that his complaint contained only one targeting claim, that Heck did not apply because he sought damages rather than release, that he was not a prisoner, and that he was not challenging a conviction or sentence. He also argued that his allegations were sufficient and requested appointment of counsel.

Court’s Analysis

The court held that seeking damages did not avoid Heck. Under that rule, a plaintiff cannot recover damages for conduct whose unlawfulness would necessarily imply that a conviction or sentence is invalid unless the conviction or sentence has already been invalidated in one of the ways recognized by the rule. The court determined that all of Linehan’s claims rested on the alleged invalidity of his civil commitment and that granting his requested relief would necessarily imply that the commitment was invalid.

The court also held that Heck’s principles apply to people confined through civil commitment rather than a prison sentence. It rejected Linehan’s argument that his “targeting” allegations were sufficient under the older pleading standard. The court explained that current pleading rules require enough facts to make a claim plausible, not merely possible, and found that Linehan identified no allegations that could save his claims in light of Heck.

The court declined to appoint counsel. It found that the relevant facts and law were neither complex nor unique, that Linehan had shown a threshold ability to present his arguments and communicate with the court, and that counsel did not appear likely to significantly benefit Linehan or the court.

Disposition

The court granted in part and denied in part Linehan’s motion to accept his objections: it granted the motion to the extent it asked the court to consider the objections and denied it to the extent it asked the court to sustain them. The court overruled Linehan’s objections, adopted Magistrate Judge Brisbois’s Report and Recommendation in its entirety, dismissed the matter without prejudice under 28 U.S.C. § 1915(e)(2)(B)(ii) for failure to state a claim, and denied Linehan’s application to proceed without paying fees as moot.