Daywitt v. MN Dept. of Human Services

Background

Kenneth Steven Daywitt, Kenneth Gernard Parks, and Tyler Paul Gephart are involuntarily committed to the Minnesota Sex Offender Program. They alleged that the Minnesota Commitment and Treatment Act was unconstitutional, that the defendants violated the Act and their due-process rights under the Fourteenth Amendment and the Minnesota Constitution, and that the defendants’ search policies violated the Fourth Amendment.

The defendants moved to dismiss under Rule 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. The case had previously been stayed while a related class action was resolved.

Reasons for the Decision

The defendants argued that claim preclusion barred the plaintiffs’ claims. Claim preclusion prevents parties or people legally connected to them from bringing claims that were already decided, or that could have been brought, in an earlier case. The court found that the earlier class action resulted in a final judgment on the merits, involved proper jurisdiction, and involved the same parties or parties legally connected to them. The plaintiffs had been class members in that action, and the remaining defendants were sufficiently connected to defendants in the earlier case.

The court also found that the claims arose from the same core facts as claims in the earlier case. The plaintiffs’ challenges to the constitutionality of the Minnesota Commitment and Treatment Act, treatment claims, punishment claims, and Fourth Amendment search claims closely matched claims in the earlier action. The court therefore held that those claims were barred by claim preclusion.

The court separately addressed the plaintiffs’ claims under the Minnesota Constitution. It concluded that Minnesota had not created a statutory claim for monetary damages for state-constitutional violations and that the Minnesota Supreme Court had not recognized such a claim. The court also concluded that injunctive relief was unavailable for these claims.

Order

The court granted the defendants’ motion to dismiss. It dismissed the plaintiffs’ claims against all defendants, in their official and individual capacities, with prejudice, and directed that judgment be entered. The opinion did not decide whether the challenged conduct actually violated the federal Constitution; the dismissal rested on claim preclusion and the unavailability of the requested relief under the Minnesota Constitution.