Dalen v. Harpstead

Background

Kyle Jerome Dalen alleged that, while under a civil commitment order and jailed on criminal charges, he was not admitted to a state-operated treatment program within the 48 hours required by the earlier version of Minn. Stat. § 253B.10, subdivision 1(b). The opinion describes his detention in the Stearns County Jail from April 3, 2023, until his admission to the Anoka-Metro Regional Treatment Center on June 6, 2023.

The Minnesota Legislature amended the statute effective May 25, 2023. Under the amended version, the 48-hour period begins when the Office of Medical Director or a designee determines that a medically appropriate bed is available, rather than when a court enters a commitment order. Dalen challenged the amendment and sought damages and other relief based on the alleged violation of the earlier rule. He asserted nine claims, including constitutional claims, claims under 42 U.S.C. § 1983, and Minnesota tort claims, on behalf of himself and a proposed class.

The case was originally filed in Dakota County District Court and removed to federal court because it included federal claims. Harpstead moved to dismiss, arguing both that Dalen lacked constitutional standing and that his claims were legally insufficient. Dalen separately moved for a preliminary injunction blocking implementation of the 2023 amendment while the case proceeded.

Standing

The court rejected Harpstead’s standing argument at this stage. It held that Dalen plausibly alleged an injury because he claimed that the alleged violation left him in jail for several weeks without treatment for mental illness and chemical dependency, and because he was subject to the amended rule during part of his detention. The court therefore treated the case as having a sufficient alleged injury for purposes of the motion.

The court did not decide whether Dalen had adequately shown an ongoing or immediate threat of future injury needed for prospective declaratory or injunctive relief. It left that issue unaddressed because Harpstead had not raised it and the available factual record was limited.

Federal Claims

The court held that Dalen’s federal claims were not plausibly alleged, meaning the amended complaint did not provide enough factual content to support a reasonable inference that Harpstead was legally liable.

For the void-for-vagueness claim, the court held that the amended statute’s requirement of a medically appropriate bed was not impermissibly vague. The court reasoned that the statute assigns the determination to a licensed psychiatrist or designee and that medical judgment does not automatically make a law unclear. The court also viewed the availability component as requiring a reasonably clear inquiry into whether an appropriate bed was available.

For the deliberate-indifference claim, the court found that the complaint did not plausibly allege that Dalen faced an objectively serious medical risk during his April 2023 detention or that Harpstead knew about such a risk at that time.

For the pretrial-punishment claim, the court found that the complaint did not describe the conditions of Dalen’s confinement or allege facts showing that those conditions were intentionally punitive, unrelated to a legitimate government purpose, or excessive in relation to that purpose.

For the unreasonable-restraints claim, the court found that the complaint did not describe any bodily restraint or professional judgment concerning a restraint. The court declined to treat pretrial detention in a jail, without more, as a restraint subject to the legal standard governing restraints of civilly committed persons.

For the substantive-due-process claim, the court held that the complaint did not plausibly allege either infringement of a fundamental right or conduct that shocked the conscience. The court also noted that Dalen cited no authority establishing that a state official’s legislative advocacy could itself violate substantive due process. Regarding the separation-of-powers claim, the court understood any federal aspect to have been waived because Dalen’s opposition relied only on the Minnesota Constitution.

Preliminary Injunction

The court denied Dalen’s motion for a preliminary injunction. It concluded that the lack of merit in the federal claims meant Dalen had not shown a likelihood of success. It also found that he had not shown irreparable harm because he had been admitted to treatment, identified no particular ongoing threat that he would again be jailed while civilly committed, and could not rely on the possible harm to an unnamed class member.

The court said the public-interest and competing-harm factors did not clearly favor either side. It noted that, absent a constitutional problem, the legislature was best positioned to weigh the competing policy concerns.

Disposition

The order states that Harpstead’s motion to dismiss was GRANTED IN PART. Dalen’s claims arising under § 1983 and/or the United States Constitution were DISMISSED WITHOUT PREJUDICE. Dalen was allowed to file a second amended complaint by February 6, 2024.

The order separately states that Dalen’s motion for a preliminary injunction was DENIED. If Dalen did not file a second amended complaint by the deadline, the federal claims would be dismissed with prejudice, judgment would be entered on those claims, and the case would be remanded to Dakota County District Court. Judgment was entered at that time only concerning the denial of the preliminary-injunction motion.