Udoh v. Janssen

Background

Emem Ufot Udoh sued Vicki Janssen and Paul Schnell, who work for the Minnesota Department of Corrections. His amended complaint alleged that they failed to provide him with meaningful access to the courts during his detention at the Minnesota Correctional Facility—Rush City.

A magistrate judge recommended granting Janssen and Schnell’s motion to dismiss and denying Udoh’s request for injunctive relief. On February 15, 2022, the district court adopted that recommendation as modified, granted the motion to dismiss, and denied the request for injunctive relief. Judgment was entered on February 16, 2022.

Motion to Amend the Judgment and for a New Trial

Udoh moved under Federal Rule of Civil Procedure 52(b) to amend the judgment and under Rule 59 for a new trial. Rule 52(b) permits changes to factual findings in an action tried without a jury, and Rule 59 permits a new trial after a jury or nonjury trial. Because no trial had occurred, the court held that those rules could not provide Udoh the requested relief. The court denied his motions to amend the judgment and grant a new trial.

Petition to Review the State-Court Decision

Udoh also asked the federal district court to review a February 8, 2022 Minnesota Court of Appeals order opinion. The court held that it lacked subject-matter jurisdiction—the authority to hear the matter—to review a state-court decision in an appellate capacity. The court therefore denied Udoh’s petition for review.

Fee Application and Disposition

The court denied Udoh’s application to proceed without prepaying fees or costs as moot. The court’s order denied Udoh’s motions to amend the judgment and grant a new trial, denied his petition for review of the Minnesota Court of Appeals decision, and denied his fee application as moot.