Benson v. Piper

Background

Michael D. Benson, representing himself, sued officers and employees of the Minnesota Department of Human Services under 42 U.S.C. § 1983, a federal law allowing claims for violations of constitutional rights by state actors. Benson was involuntarily committed to the Minnesota Sex Offender Program. His remaining claims alleged that he was denied food for three days, placed in wrist restraints, improperly placed in the High Security Area, and unreasonably searched.

The parties filed competing motions for summary judgment. The magistrate judge recommended granting the defendants’ motion and dismissing Benson’s remaining claims. Benson did not object. The court adopted that recommendation on August 19, 2020, entered judgment the next day, and Benson did not appeal.

Motion to Vacate

Benson later moved under Federal Rule of Civil Procedure 60(b) to vacate the order and judgment. Because he relied on a change in the law, the court treated the motion as arising under Rule 60(b)(6), which permits relief from a final judgment for other reasons that justify relief. Relief under that provision is available only in extraordinary circumstances.

Benson relied on the Eighth Circuit’s decision in Karsjens v. Lourey. That decision held that claims by civilly committed people alleging punitive conditions of confinement should not be evaluated under the “shocks the conscience” standard. Instead, courts should use the Bell standard, which asks whether the conditions were imposed as punishment or were incidents of another legitimate governmental purpose.

Court’s Analysis

The court agreed that the “shocks the conscience” standard was no longer the correct standard for Benson’s Fourteenth Amendment claims concerning punitive conditions of confinement. But it held that this change in law, by itself, was not an extraordinary circumstance justifying relief from a final judgment. The court emphasized that Benson had a full and fair opportunity to litigate his claims and had not timely appealed.

The court also held that the change in law would not alter the result. Although the earlier recommendation had applied the “shocks the conscience” standard, it had also found that each alleged punitive condition was connected to a legitimate governmental interest. The court therefore concluded that Benson’s claims would fail under the Bell standard as well.

Disposition

The court ordered that Benson’s pro se motion to vacate the order and judgment adopting the magistrate judge’s recommendation was DENIED. The opinion also notes that defendant Ron Fischer died while the litigation was pending and that Benson did not file a motion to substitute a party, but the court stated that this did not affect the disposition.