Lidel v. Bosch
- Katherine Menendez
- 0:22-cv-02918
- U.S. District Court · District of Minnesota
- 3
In Lidel v. Bosch, Judge Menendez dismissed without prejudice Lidel’s damages claims against officials in their official roles because the court lacked jurisdiction.
Ricky Lee Lidel’s Section 1983 official-capacity claims for monetary damages against the defendants named in his amended complaint were dismissed without prejudice for lack of subject-matter jurisdiction. The order did not state a disposition for his individual-capacity claims.
What happened
Lidel v. Bosch concerns Ricky Lee Lidel’s amended lawsuit against Minnesota correctional officials and doctors. He sued the defendants in both their individual and official roles, seeking damages.
A magistrate judge recommended dismissing the official-capacity claims because they were effectively claims against Minnesota, and the state had not consented to this type of lawsuit. Lidel did not identify a specific error and said he elected to sue the defendants individually.
Judge Katherine M. Menendez accepted the recommendation and dismissed Lidel’s Section 1983 official-capacity claims for monetary damages without prejudice for lack of subject-matter jurisdiction.
The detailed version
- Lidel v. Bosch · No. 0:22-cv-02918
- Katherine Menendez
- July 13, 2023
Background
Ricky Lee Lidel, who is incarcerated at the Minnesota Correctional Facility in Faribault, Minnesota, filed an amended complaint naming Jesse Pugh, Paul Schnell, Deb Zinken, Robert Fornal, and William Mays as defendants. The amended complaint identified Pugh as a warden, Schnell as the commissioner of the Minnesota Department of Corrections, and the other defendants as doctors who allegedly work at Minnesota correctional facilities. Lidel sued all of them in both their individual and official capacities.
A prior court order found that Lidel’s complaint violated the federal rules governing the joinder of claims and defendants and ordered him to file an amended complaint. After reviewing the amended complaint, Magistrate Judge Leo I. Brisbois issued a report and recommendation. The report concluded that the official-capacity claims were effectively claims against the State of Minnesota. It further concluded that the Eleventh Amendment barred those damages claims, that Section 1983 does not overcome that immunity, and that officials sued in their official capacities are not “persons” subject to such damages claims under Section 1983. The report recommended dismissal without prejudice for lack of subject-matter jurisdiction.
Objections
Lidel filed objections to the report and recommendation. The district court understood Lidel’s filing as abandoning the official-capacity claims and electing to pursue claims against the defendants individually and jointly for compensatory and punitive damages. The court found that Lidel did not object to any specific finding or conclusion in the report. It also found no error in the report’s analysis.
Ruling
Judge Katherine M. Menendez accepted the report and recommendation. The court ordered that Lidel’s Section 1983 official-capacity claims for monetary damages be dismissed without prejudice for lack of subject-matter jurisdiction. The order did not state a disposition for Lidel’s individual-capacity claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.