Jackson v. Simon

Background

Tony Dejuan Jackson brought an action under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state officials, against Steve Simon and Paul Schnell. Jackson alleged that his constitutional and statutory voting rights were violated because he was incarcerated after several felony convictions and therefore could not vote. He asserted claims under the Eighth, Thirteenth, and Fourteenth Amendments, the Voting Rights Act of 1965, and 42 U.S.C. §§ 1985 and 1986.

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim for relief.

Constitutional claims

The court held that Jackson did not plausibly state a constitutional claim. It explained that incarcerated people do not have a fundamental right to vote and cited the Fourteenth Amendment and Richardson v. Ramirez in support of the constitutionality of felony disenfranchisement.

The court rejected Jackson’s Eighth Amendment claim because he did not allege facts showing that preventing people convicted of felonies from voting was cruel and unusual punishment. His allegations about conditions at his facility also did not plausibly show an Eighth Amendment violation or connect those conditions to his inability to vote.

The court rejected the Thirteenth Amendment claim because that amendment prohibits slavery and involuntary servitude and does not prohibit disenfranchising people convicted of felonies during or after incarceration.

The court also rejected Jackson’s Fourteenth Amendment equal-protection claim. Although Jackson alleged that Black men are disproportionately affected because they make up a higher percentage of Minnesota’s incarcerated population, the court found that he had not alleged that Black prisoners were treated differently from similarly situated people of other races or that the defendants intentionally discriminated against him. The court further stated that Minnesota’s law would survive rational-basis review.

Voting Rights Act and prison-gerrymandering claims

The court held that any claim under Section 5 of the Voting Rights Act failed because Section 5 had never applied to Minnesota. The court construed Jackson’s prison-gerrymandering allegations as potentially asserting a claim under Section 2, but found that he had provided only conclusory allegations. In particular, he did not plead facts satisfying the requirements for a Section 2 vote-dilution claim, including facts about the size and geographic compactness of the incarcerated Black population, political cohesion, and bloc voting by a white majority.

Because Jackson did not sufficiently allege a civil-rights violation, the court also held that his claims under Sections 1985 and 1986 failed.

Additional filing

Jackson filed an additional memorandum after the authorized briefing. The court said that sur-replies were not permitted under the applicable local rules or the court’s briefing order and therefore did not consider the filing. The court also stated that the filing’s allegations about prison conditions and filing sanctions were not raised in the complaint.

Disposition

The court granted the defendants’ motion to dismiss. The order states that the matter was dismissed with prejudice and directs that judgment be entered. The classification is procedural because the order disposed of the case through a Rule 12(b)(6) motion, even though the court also discussed why Jackson’s claims failed as a matter of law.