Favors v. Johnston

Background

Joseph Anthony Favors sued Nancy Johnston and Jodi Harpstead over Minnesota Sex Offender Program restrictions on purchases from outside vendors. Favors alleged that MSOP clients had to buy items such as food and drinks from MSOP-approved sources, even when the same items might cost less elsewhere. He claimed that the restrictions violated federal constitutional rights and state statutory provisions.

The court considered Favors’s application to proceed without paying the filing fee, known as an application to proceed in forma pauperis, and his later motion to amend his pleading. Because he sought that status, the court screened the complaint under 28 U.S.C. § 1915(e)(2)(B), which requires dismissal of claims that fail to state a valid legal claim.

Federal Claims

The court rejected Favors’s claim that the purchasing restrictions themselves violated his constitutional rights. Applying the modified framework used in this District for constitutional challenges by MSOP residents, the court considered whether the policy was reasonably related to legitimate therapeutic and institutional interests. It found that MSOP officials had an institutional and safety interest in controlling the goods entering the facility and that Favors had not identified any part of the policy unrelated to that interest.

The court also rejected Favors’s equal-protection claim. Favors alleged that other MSOP clients had been allowed to make outside purchases and expressly presented a “class-of-one” theory, meaning that he claimed he alone was treated differently. The court held that he did not provide enough specific facts showing that a truly comparable MSOP client received more favorable treatment. The court also noted Favors’s suggestion that some clients with greater privileges had agreed to participate in sex-offender treatment, which could mean they were not similarly situated.

The court rejected Favors’s procedural-due-process claim based on the Minnesota Health Care Bill of Rights. It held that the cited state law did not create the type of protected liberty interest requiring procedural protections and noted that enforcement authority rested with the state health commissioner, subject to the statute’s grievance procedures.

The court further rejected Favors’s substantive-due-process claim. It held that the restrictions were not irrational or conscience-shocking because they were reasonably related to MSOP’s institutional needs. It likewise found that the alleged purchasing restrictions did not plausibly amount to unsafe or constitutionally deficient living conditions under the Eighth and Fourteenth Amendments.

State-Law Claims and Jurisdiction

The remaining claims arose under state law. The court held that 28 U.S.C. § 1331 did not provide original jurisdiction because those claims did not arise under federal law. It also stated that Favors did not allege diverse citizenship that could provide jurisdiction under 28 U.S.C. § 1332(a). Because all federal claims were dismissed before trial, the court declined to exercise supplemental jurisdiction over the state-law claims.

Disposition

The court stated that Favors’s financial eligibility for fee-waiver status was irrelevant because his complaint failed to state a claim. It nevertheless expressed substantial doubts about his financial eligibility because he did not provide all requested account information and acknowledged having sufficient funds to seek permission to purchase a second musical keyboard.

The order granted Favors’s motion to amend, denied his application to proceed in forma pauperis, and dismissed the matter without prejudice. The federal claims were dismissed under 28 U.S.C. § 1915(e)(2)(B), and the state-law claims were dismissed for lack of jurisdiction.