Jackson v. Schnell
- Katherine Menendez
- 0:22-cv-03074
- U.S. District Court · District of Minnesota
- 4
In Jackson v. Schnell, Judge Menendez denied Jackson’s objection and adopted a recommendation denying two requests for emergency injunctive relief.
Tony Dejuan Jackson’s two requests for emergency injunctive relief were denied; the order also denied his objection and adopted the magistrate judge’s recommendation.
What happened
Jackson v. Schnell involved Tony Dejuan Jackson’s requests for emergency court orders concerning access to legal materials and prison staffing. His underlying complaint alleged that he was being exposed to toxic lead at a prison facility and that this threatened his health.
Magistrate Judge Douglas L. Micko recommended denying both requests. The court concluded that the requested orders were not sufficiently connected to the claims in Jackson’s complaint. It also concluded that Jackson had not shown the immediate risk of serious, lasting harm required for a preliminary injunction.
Judge Katherine Menendez overruled Jackson’s objections, adopted the recommendation in full, and denied his objection. The court therefore left in place the denial of both requests for emergency injunctive relief and ordered that judgment be entered.
The detailed version
- Jackson v. Schnell · No. 0:22-cv-03074
- Katherine Menendez
- Jan. 11, 2024
Background
Tony Dejuan Jackson sued Paul Schnell and Guy Bosch. His amended complaint alleged that he had not been provided a prison facility free of toxic lead, which he said endangered his health and caused various physical symptoms.
Jackson filed two motions seeking emergency relief: one requested improved access to legal materials, and the other requested changes to prison staffing practices. Magistrate Judge Douglas L. Micko issued a Report and Recommendation recommending that both motions be denied. Jackson objected, and Schnell and Bosch responded.
Legal standard
The court explained that a preliminary injunction is an emergency order intended to preserve the existing situation and prevent serious harm until the court can decide the lawsuit. Courts consider the moving party’s likelihood of success, the threat of irreparable harm, the balance of harms to the parties, and the public interest. The requested emergency relief must also be connected to the claims in the complaint.
Because Jackson specifically objected to the Report and Recommendation, Judge Menendez reviewed the challenged portions of the record independently. The court noted that objections that merely repeat arguments already presented to the magistrate judge do not receive that independent review.
Court’s reasoning
The court agreed with Judge Micko that Jackson had not shown the necessary connection between his requested relief and the claims in this case. The complaint concerned alleged toxic-lead exposure, while the two motions sought changes involving legal materials and prison staffing.
The court also stated that, even if it considered the motions under the four preliminary-injunction factors, Jackson still had not shown the imminent risk of irreparable harm required for that relief. The court noted that the record showed Jackson had been able to litigate the case vigorously and that he had not made the required showing of irreparable harm from staffing levels.
Disposition
The court adopted Magistrate Judge Micko’s August 17, 2023, Report and Recommendation in its entirety. Judge Menendez denied Jackson’s objection to that recommendation. The court stated that Jackson’s two motions for emergency injunctive relief were properly denied and ordered that judgment be entered.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.