Hageman v. Minnesota Department of Corrections

Background

Adam Hageman, representing himself, filed an amended complaint against the Minnesota Department of Corrections and numerous correctional officials. He alleged more than a dozen constitutional violations arising from the department’s response to the COVID-19 pandemic, along with state-law claims. The magistrate judge recommended dismissal of the amended complaint without prejudice under the prisoner-complaint screening statute, 28 U.S.C. § 1915A(b), and recommended denying Hageman’s application to proceed without prepaying fees or costs as moot.

Hageman objected to that recommendation. The district court reviewed specific objections in detail and reviewed less-specific objections for clear error. Because Hageman was representing himself, the court read his filings liberally, but it did not assume facts that he had not pleaded.

Court’s Analysis

The court agreed that Hageman’s constitutional claims against the individual defendants lacked sufficient factual detail or a sound legal basis to state plausible claims. Among other things, Hageman did not adequately connect particular defendants to the alleged misconduct, did not explain why postponing an appointment with Dr. Kerri Chung because of the coronavirus amounted to deliberate indifference to serious medical needs, and did not identify or connect alleged policies and customs to constitutional violations.

The court also found that Hageman’s conspiracy and retaliation allegations were legal conclusions without enough supporting facts. His allegations about threats by Quist and Bosch did not identify the alleged threat-makers in the amended complaint or describe the threats. The court further held that Quist’s statement that Hageman could file a lawsuit did not waive Minnesota’s immunity or consent to suit against the Minnesota Department of Corrections. The court explained that the state-immunity ruling concerned the department itself, not official-capacity claims seeking prospective injunctive relief against individual officials.

Because the federal claims were not plausibly pleaded, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over Hageman’s state-law claims.

Disposition

Judge Susan Richard Nelson overruled Hageman’s objection, adopted the magistrate judge’s report and recommendation in its entirety, dismissed Hageman’s amended complaint without prejudice, and denied his application to proceed without prepaying fees or costs as moot. The court directed that judgment be entered accordingly.