Hageman v. Minnesota Department of Corrections

Background

Adam Hageman, Dane Vander Voort, and Paul Primrose, proceeding without lawyers, sued the Minnesota Department of Corrections and several named officials and employees under 42 U.S.C. § 1983. They alleged that prison staff harassed Vander Voort, retaliated against the plaintiffs after they reported alleged misconduct and participated in an internal investigation, interfered with legal mail and access to legal and religious resources, and violated their speech, religious-freedom, due-process, and petition rights. They also alleged that officials failed to take adequate measures to prevent the spread of COVID-19, including by failing to enforce mask-wearing.

The plaintiffs sought a preliminary injunction concerning prison conditions. Magistrate Judge Becky Thorson issued two Reports and Recommendations. The first recommended dismissing certain harassment and retaliation claims, dismissing the COVID-19 claims, and denying the preliminary-injunction motion without prejudice. The second recommended granting the defendants’ motion to dismiss the remaining claims and denying the plaintiffs’ motions for a temporary restraining order and to compel discovery as moot. The plaintiffs objected to both recommendations.

Court’s Analysis

The court overruled the objections and adopted both Reports and Recommendations. It explained that the plaintiffs’ objections largely repeated their earlier arguments or stated legal conclusions without specifically identifying an error, so those objections did not warrant a fresh review of the challenged portions.

For the harassment and retaliation claims, the court held that claims against the defendants in their official capacities were barred by the Eleventh Amendment. The court also held that the defendants were entitled to qualified immunity for claims against them in their individual capacities because the plaintiffs had not plausibly established a constitutional violation. Qualified immunity generally protects government officials from personal liability unless their conduct violated a clearly established statutory or constitutional right.

The court also dismissed the COVID-19 claims for failure to state a claim. It found that the alleged scattered failures to wear masks or protective equipment, and the allegation that Defendant Menne contracted COVID-19, did not establish that any defendant acted with deliberate indifference. The court noted that the complaint did not allege that Menne worked while infected or that the plaintiffs were exposed to him while he knew or should have known he was infected. It also did not adequately allege that Schnell or Reimann knew about the alleged protective-equipment failures or that the plaintiffs faced an increased infection risk because of them.

Disposition

Judge John R. Tunheim ordered that the plaintiffs’ objections be overruled and both Reports and Recommendations be adopted. The defendants’ motion to dismiss was granted. The plaintiffs’ motion opposing dismissal was denied without prejudice. Their motions for a temporary restraining order, preliminary injunction, and to compel discovery were each denied without prejudice as moot. The action was dismissed without prejudice, and the court directed that judgment be entered.