Jackson v. Find Jodi. Com, Inc

Background

Tony Dejuan Jackson, who was incarcerated and proceeding without a lawyer, filed a complaint asserting dozens of unrelated claims against approximately 21 parties. The claims ranged from slander, money laundering, and conspiracy to allegations about prison conditions, sentencing, and denial of mandatory sex-offender treatment.

Magistrate Judge Leo I. Brisbois screened the complaint under 28 U.S.C. § 1915A, a statute requiring courts to review certain complaints filed by incarcerated people. He recommended dismissing Jackson’s claims against the United States District Court for the District of Minnesota with prejudice because of sovereign immunity, which generally protects the federal government and its agencies from lawsuits. He recommended dismissing Jackson’s remaining claims without prejudice because they were inadequately pleaded and did not satisfy the rules for joining multiple defendants and claims in one case.

After the recommendation, Jackson filed an objection and an amended complaint. The amended complaint did not address the deficiencies identified in the recommendation and added Magistrate Judge Brisbois as a defendant. The court found that claim against Brisbois frivolous and futile because judges are generally immune from civil suits based on conduct performed as part of their judicial duties.

Issues and analysis

Jackson argued that all federal judges in Minnesota were disqualified from deciding his case based on an order in a different case. The court rejected that argument, explaining that the earlier order did not control this case and that Jackson had not shown a basis for disqualifying the judges here.

The court held that the District of Minnesota was protected by sovereign immunity. Jackson did not show that the United States had waived that immunity, so the claims against the court could not proceed.

The court declined to consider Jackson’s argument that an “imminent danger” exception allowed him to proceed without paying filing fees because he had not presented that argument to the magistrate judge. The court also concluded that his complaint failed to satisfy the basic pleading requirements of Federal Rule of Civil Procedure 8(a)(2) and did not satisfy the more specific requirements for fraud claims under Rule 9(b). In addition, the complaint did not show that the claims against the multiple defendants arose from the same transaction or occurrence or involved common questions of law or fact, as required to join defendants under Rule 20(a)(2).

Finally, the court rejected Jackson’s claim that Magistrate Judge Brisbois was biased. It concluded that the magistrate judge correctly explained that it was Jackson’s responsibility to state his claims and that the judge was not required to search the exhibits for possible legal theories.

Disposition

Judge Susan Richard Nelson overruled Jackson’s objection and adopted the report and recommendation in its entirety. The court dismissed the complaint and amended complaint as follows:

- Claims against the “United States District of Minnesota” and Magistrate Judge Brisbois were dismissed with prejudice. - Jackson’s remaining claims were dismissed without prejudice. - Jackson’s application to proceed without prepaying fees or costs was denied as moot. - His motions concerning service, free copies of documents, appointment of counsel, and relation-back amendments were denied as moot.