Benson v. Harpstead

Background

Michael D. Benson, representing himself, was involuntarily committed to the Minnesota Sex Offender Program. In January 2017, he sued officers and employees of the Minnesota Department of Human Services under 42 U.S.C. § 1983, a federal law allowing claims against state actors for violating constitutional rights. His remaining claims alleged First Amendment retaliation, Fourth Amendment violations based on unclothed visual body searches, and Fourteenth Amendment procedural due process violations based on placement in the program’s High Security Area.

The defendants moved for summary judgment, which asks the court to rule because the record shows no genuine dispute requiring a trial. On July 29, 2020, the magistrate judge recommended granting that motion and dismissing Benson’s claims. Benson did not object. The district court adopted the recommendation on August 19, 2020, entered judgment the next day, and Benson did not appeal.

Benson then filed a motion under Federal Rule of Civil Procedure 60 to vacate, or set aside, the earlier order and judgment. He relied on the Eighth Circuit’s 2021 decision in Karsjens v. Lourey, arguing that it changed the law by making the “shocks the conscience” standard inapplicable to his claims.

Analysis

The court treated Benson’s motion as arising under Rule 60(b)(6), the rule’s catchall provision allowing relief from a final judgment for another reason that justifies relief. The court explained that this form of relief is available only in extraordinary circumstances and is not a substitute for a timely appeal.

The court held that a change in law, by itself, was not an extraordinary circumstance warranting relief. Benson had also had a full and fair opportunity to litigate his claims, did not object to the recommendation, and did not appeal.

The court further held that Karsjens would not change the result even if a change in law could sometimes justify relief. Karsjens required courts to use the standard from Bell v. Wolfish for Fourteenth Amendment substantive due process claims alleging punitive conditions of confinement. Under that standard, the question is whether the challenged conditions were imposed as punishment or were instead an incident of a legitimate governmental purpose. The court found that the magistrate judge had already applied this standard to Benson’s High Security Area claim and had dismissed that claim after finding that the placements were reasonably related to maintaining security and order at the program.

Disposition

The court concluded that the change in law was insufficiently extraordinary to justify vacating the judgment and that, in any event, Karsjens had no effect on Benson’s case. Judge Donovan W. Frank therefore denied Benson’s pro se Rule 60 motion to vacate the earlier order and judgment.