Senty-Haugen v. Jesson
- Dulce Foster
- 0:14-cv-03405
- U.S. District Court · District of Minnesota
- 8
In Senty-Haugen v. Jesson, Judge Foster granted fee waivers, separated Benson’s claims, and ordered steps toward serving defendants.
The order directly affected plaintiffs Arthur Dale Senty-Haugen, Russell John Hatton, and Brandon Keith Benson, and set procedures for serving the named defendants.
What happened
Senty-Haugen v. Jesson concerns three people who were civilly detained at the Minnesota Sex Offender Program when they filed a lawsuit about conditions there. The case had been paused for years while a related case was decided. The court considered whether the plaintiffs qualified as prisoners under a federal law that requires prisoners to pay filing fees over time and concluded that none did.
The court also addressed how the plaintiffs could continue the case without lawyers after Senty-Haugen moved to a federal prison in California. Because one unrepresented person cannot represent another, Benson asked to separate his claims and file a new complaint focused on his own circumstances. The court determined that separation could preserve his ability to pursue claims that might otherwise become untimely.
Judge Foster granted all three plaintiffs permission to proceed without paying the filing fee upfront, granted Benson’s request to separate his claims, and granted him permission to file a second amended complaint in a new case by January 9, 2023. Senty-Haugen and Hatton remained in the original case and were ordered to provide forms needed for service; the court did not decide whether their claims were legally valid.
The detailed version
- Senty-Haugen v. Jesson · No. 0:14-cv-03405
- Dulce J. Foster
- Dec. 9, 2022
Background
Arthur Dale Senty-Haugen, Russell John Hatton, and Brandon Keith Benson filed this action in 2014 concerning the legality of conditions at the Minnesota Sex Offender Program. All three were civilly detained there when they filed. The court had stayed the case shortly after filing while a related case was decided, and lifted the stay in October 2022.
Senty-Haugen later became a federal prisoner in California, while Hatton and Benson remained detained at the Minnesota Sex Offender Program. None of the plaintiffs was represented by a lawyer. Benson moved to sever, meaning to separate, his claims from the other plaintiffs’ claims, and moved for permission to file a second amended complaint concerning only his own claims.
Prison Litigation Reform Act status
The court first considered whether the plaintiffs were “prisoners” under the Prison Litigation Reform Act. That law generally requires prisoners to pay the filing fee in installments. The court applied the plaintiffs’ status when they filed the case, rather than Senty-Haugen’s later status as a federal prisoner.
The court held that civil detention for nonpunitive purposes does not by itself make someone a prisoner under the Act. It also rejected treating Senty-Haugen and Benson as prisoners merely because they had criminal charges pending when they filed. The court found that their detention at the Minnesota Sex Offender Program did not result from those criminal charges. It therefore concluded that none of the three plaintiffs was a prisoner for purposes of the Act.
Severance and amendment
The court explained that one unrepresented person cannot litigate on behalf of another unrepresented person. Because Senty-Haugen and Benson were at different facilities, the court found it difficult for the plaintiffs to continue prosecuting the case jointly. The court also stated that a new lawsuit by Benson concerning events from 2014 would almost certainly be untimely, while noting that the long stay in this case was the reason he had been unable to litigate earlier.
The court granted Benson’s motion to sever. It directed the Clerk of Court to begin a new civil proceeding naming Benson as the sole plaintiff. The existing amended complaint would begin that proceeding and remain the operative pleading there. The court also granted Benson leave to file a second amended complaint by January 9, 2023. That future complaint would remain subject to the court’s required review before service.
Order
The court granted all three plaintiffs’ applications to proceed without paying the filing fee upfront. It granted Benson’s motion to sever and motion to amend. It did not separate Senty-Haugen and Hatton because neither requested severance or indicated an intention to file an individual amended complaint.
The court ordered Senty-Haugen and Hatton to submit completed forms for each defendant so the United States Marshals Service could arrange service. If they did not return the forms within 30 days of the order, the court would recommend dismissal of the matter without prejudice for failure to prosecute. The court also directed the Clerk to seek waivers of service from defendants in their personal capacities and directed the Marshals Service to serve defendants in their official capacities as agents of the State of Minnesota.
The order addressed filing-fee status, case organization, amendment, and service. It did not decide whether the plaintiffs’ underlying claims about conditions at the Minnesota Sex Offender Program were legally valid.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.