Bethune v. St. Paul Social Security
- Paul Magnuson
- 0:21-cv-02644
- U.S. District Court · District of Minnesota
- 4
In Bethune v. St. Paul Social Security, Judge Magnuson dismissed the action without prejudice for lack of jurisdiction and denied fee-waiver and counsel requests as moot.
Jason Lavet Bethune’s action was dismissed without prejudice; his fee-waiver application and request for appointed counsel were denied as moot. The opinion did not decide the merits of his allegations against the named defendants.
What happened
In Bethune v. St. Paul Social Security, Jason Lavet Bethune filed a one-page document accusing Social Security personnel and three named individuals of changing his records and retaliating against him. He listed several alleged legal violations and requested $220 billion in damages.
The court said Bethune had not shown that he completed the Social Security Administration’s required administrative process or received a final decision that a federal court could review. Because the court could not determine that it had authority to hear the case, it dismissed the action without prejudice.
Judge Magnuson also denied Bethune’s application to proceed without paying court fees and his request for a lawyer as moot. The dismissal did not prevent refiling, as the court expressly stated that it was without prejudice.
The detailed version
- Bethune v. St. Paul Social Security · No. 0:21-cv-02644
- Paul Magnuson
- Jan. 14, 2022
Background
Jason Lavet Bethune submitted a one-page initial filing that the court treated as an attempted complaint. It named “Mr. Jimmy,” “Mr. Shia,” “Mr. Haggus,” and “St. Paul Social Security ALL,” which the court understood as an attempt to sue all employees of the Social Security office in St. Paul, Minnesota.
Bethune alleged in two sentences that defendants made “improper changes” to his file and retaliated against him for suing the Social Security office. He said this caused hardship to him and his family. The filing listed alleged violations involving disability rights, racial intimidation, civil rights, the Fourth Amendment, the First Amendment, assault, theft by deception, and trademark infringement. It requested $220 billion in damages. The filing also referred to the St. Cloud Social Security office, although the court said it was unclear whether Bethune meant that office or the St. Paul office.
Jurisdiction
Bethune applied to proceed without paying filing fees and asked the court to appoint a lawyer. The court noted that the financial information in his application appeared to show that he qualified financially for fee-waiver status. But the court explained that a case must be dismissed if the court lacks subject-matter jurisdiction, meaning the legal authority to hear the dispute.
The court understood Bethune’s allegations as challenging decisions or record changes by Social Security Administration personnel. Under 42 U.S.C. § 405(g), the court explained, federal judicial review is generally available only for a final Social Security decision made after the required administrative process. Bethune gave no indication that he had completed that process for the alleged improper changes. The court therefore concluded that he had not shown a basis for subject-matter jurisdiction.
Disposition
The court dismissed the action without prejudice for lack of subject-matter jurisdiction. “Without prejudice” means the dismissal did not bar a later filing, although the opinion did not decide whether Bethune could ultimately prevail on his allegations. The court denied the application to proceed without paying fees and the request for appointment of a lawyer as moot, meaning those requests no longer required a decision after the case was dismissed.
Judge Paul A. Magnuson ordered that judgment be entered accordingly.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.