Wilson v. Ramsey County ADC Jail

Background

Edward Wilson filed seven separate actions concerning medical issues he experienced while incarcerated. Two were before this court.

In case No. 23-1991, Wilson alleged that the Ramsey County Adult Detention Center administered the wrong medication twice, causing irregular heartbeats and other symptoms. He sought $100 million in damages. The magistrate judge determined that the closest federal claim was deliberate indifference to serious medical needs under 42 U.S.C. § 1983, a statute that allows certain civil-rights claims against state actors. The magistrate judge concluded that Wilson had not alleged that prison officials knew of and disregarded a serious medical need and had not identified specific defendants who caused his harm. The recommendation was dismissal without prejudice under the prisoner-screening statute, 28 U.S.C. § 1915A.

In case No. 23-1993, Wilson sought $100 million from the Ramsey County Adult Detention Center after contracting influenza. The magistrate judge concluded that Wilson had sued the wrong defendant and had not plausibly alleged willful disregard of his medical needs. That recommendation also called for dismissal without prejudice under § 1915A.

Wilson later sent letters asking the court to amend his complaints by adding individual defendants and federal and state-law claims. The court explained that Wilson had to file any amended pleading himself. Under the applicable local rule, an amended pleading had to be complete on its own and could not incorporate an earlier pleading by reference.

Screening and jurisdiction

The Prison Litigation Reform Act requires courts to screen a prisoner’s civil action against a government entity, officer, or employee. The court must determine whether the action is frivolous, malicious, fails to state a claim, or seeks money from an immune defendant.

Because Wilson filed no objections to either report and recommendation, Judge Tunheim reviewed them for clear error. The court found no clear error. Even construing Wilson’s complaints favorably and treating them as attempts to bring § 1983 claims, the complaints did not plausibly allege deliberate indifference to a serious medical need.

The court also concluded that Wilson had not plausibly established jurisdiction over state-law claims. It stated that Wilson did not allege diversity of citizenship, and the failure of his federal claim meant there was no original federal jurisdiction supporting supplemental jurisdiction over related state-law claims.

Motions to access records

The court denied Wilson’s motions asking it to obtain his correctional-facility grievance history and medical records. It reasoned that those records would not prevent dismissal because the complaints and materials attached to or incorporated into them had to state a claim on their own. The court also stated that a litigant, rather than the court, ordinarily must locate and provide relevant information, and that the court could not conduct discovery on Wilson’s behalf.

Consolidation and filing fees

The court found that the two cases before it involved sufficiently related medical incidents to be handled together. Under Federal Rule of Civil Procedure 42, it consolidated case Nos. 23-1991 and 23-1993 into a single action under case number 23-1991. It stated that it could not alter filing fees in Wilson’s five other cases, which were not before it.

For the consolidated cases, however, the court required only one $350 filing fee. It overruled the earlier order insofar as it required payment of the statutory filing fee in case No. 23-1993 and directed the Clerk to withdraw the payment notice for that case.

Order

Judge Tunheim adopted the two magistrate judges’ reports and recommendations. The court consolidated the two cases, directed that future filings be submitted under case number 23-1991, denied Wilson’s motions to access grievance history, withdrew the unpaid-fee notice for case No. 23-1993, and dismissed Wilson’s consolidated action without prejudice. The opinion did not decide the underlying medical-negligence allegations on their merits.