Meranelli v. Minnesota Department of Human Services

Background

Cherrity Honesty-Alexis Meranelli, who represented herself, sued the Minnesota Department of Human Services, the Minnesota Sex Offender Program, State Operated Services, Commissioner Jodi Harpstead, and numerous other defendants. The complaint included Section 1983 claims, which are claims alleging violations of federal rights by people acting under state law, along with requests for a temporary restraining order and preliminary injunction.

United States Magistrate Judge Tony N. Leung issued a Report and Recommendation on January 11, 2024. No objections were filed within the 14-day period. Meranelli later filed objections on February 9, 2024, after the period had ended. The court reviewed the recommendation for clear error and found none, but it also briefly addressed Meranelli’s late objections.

Objections

The court rejected Meranelli’s objection that claims dismissed under Federal Rule of Civil Procedure 12(b)(1) should not have been dismissed with prejudice. It held that claims against the Minnesota Sex Offender Program, State Operated Services, and defendants sued in their official capacities for damages were barred by Eleventh Amendment immunity. Because the court viewed those claims as constitutionally barred, it held that dismissal with prejudice was appropriate.

The court also rejected the objection concerning materials considered on the motion to dismiss. It explained that such motions generally are decided using the complaint and materials necessarily embraced by the pleadings. The court found that the magistrate judge properly considered materials explicitly referenced by the pleadings and did not improperly convert the motion into one for summary judgment.

On the failure-to-protect issue, the court held that the fact an assault eventually occurred did not establish the risk known to staff beforehand. It found that Meranelli’s allegations about the circumstances known to staff before the assault were insufficient to show a substantial risk of serious harm. The court therefore overruled that objection.

The court rejected the objection that a temporary restraining order and preliminary injunction could not be denied while deciding a motion to dismiss. It stated that the requests appeared in the complaint, that a judge could address motions in that sequence or together, and that the magistrate judge had analyzed the appropriate factors. The court also rejected the objection concerning amendment, finding that jurisdictional problems could not be cured on many claims and noting that amendment is discretionary, particularly when the plaintiff has not submitted a proposed amended complaint.

Disposition

Judge Jerry W. Blackwell accepted the Report and Recommendation and ordered that the defendants’ motion to dismiss be granted in part:

- Claims against the Minnesota Sex Offender Program and State Operated Services were dismissed with prejudice under Rule 12(b)(1) and the Eleventh Amendment. - Claims for damages against defendants sued in their official capacities were dismissed with prejudice under Rule 12(b)(1) and the Eleventh Amendment. - Section 1983 claims against the Minnesota Department of Human Services, the Minnesota Sex Offender Program, State Operated Services, and official-capacity defendants were dismissed without prejudice under Rule 12(b)(6) for failure to state a claim. - Section 1983 claims against individual-capacity defendants were dismissed without prejudice under Rule 12(b)(6). - Requests for a temporary restraining order and preliminary injunction were denied. - The remaining claims were dismissed without prejudice.

The order directed that judgment be entered.