Wilson v. Ramsey County

Background

Edward Wilson, identified as a prisoner, alleged that he was given incorrect medication twice while incarcerated at the Ramsey County Adult Detention Center in 2022. He alleged that after the second incident he vomited blood, felt poisoned, and experienced irregular heartbeats. He sought $100 million in damages. The defendants named in the complaint were Ramsey County, the Medical Department, and the Department of Justice.

Filing fee

The court had previously directed Wilson to pay an initial partial filing fee of at least $23.09 and had recommended dismissal when he did not respond. Wilson later requested more time, stating that he could not make the payment. Applying 28 U.S.C. § 1915(b)(4), the court found that he had no assets or means to pay the initial fee. It therefore waived that payment requirement and vacated the prior recommendation to dismiss for failure to pay it.

Screening of the complaint

The court then reviewed the complaint under 28 U.S.C. § 1915A, which requires screening of a prisoner’s complaint against a governmental entity or government official. The court explained that a complaint may be dismissed if it is frivolous, malicious, fails to state a claim, or seeks money from an immune defendant.

The complaint did not identify a cause of action or state whether Wilson was proceeding under federal law, state law, or both. The court considered whether the allegations could support a federal deliberate-indifference claim under 42 U.S.C. § 1983. Such a claim would require facts showing that officials knew about and disregarded a serious medical need. The court found that Wilson alleged carelessness, but not that jail officials deliberately ignored or were willfully blind to his medical needs.

The court also explained that a damages claim under § 1983 generally requires identifying the specific defendant responsible for the alleged constitutional violation. Wilson did not allege that any named defendant itself caused the harm or that a Ramsey County policy or custom caused it. The people allegedly responsible for the individual misconduct were not named as defendants.

The court stated that the allegations more naturally suggested state-law claims such as negligence or medical malpractice. But Wilson did not plead facts establishing federal jurisdiction over those claims, and the court could not use supplemental jurisdiction because it found no viable federal claim. It therefore recommended dismissal without prejudice: possible federal claims under § 1915A and possible state-law claims for lack of jurisdiction.

Disposition and fee obligation

Judge Docherty ordered that the earlier August 16, 2023 Report and Recommendation be vacated. He also ordered Wilson to pay the unpaid balance of the statutory $350 filing fee through installments and directed the Clerk to notify officials at the institution where Wilson was confined. The Recommendation further recommended that the action be dismissed without prejudice and that Wilson’s application to proceed without paying the fee upfront be denied.

The notice stated that the Report and Recommendation was not itself a district-court order or judgment and was not directly appealable to the Eighth Circuit. It allowed the parties to file specific written objections within 14 days after service.