Meranelli v. Pruette

Background

Cherrity Honesty-Alexis Meranelli alleged that Jesse Ryan Pruette, a security counselor at the Minnesota Sex Offender Program, prohibited her from owning a transparent lace cover-up while allowing another transgender female resident on the same unit to own the same type of item. Meranelli referred to that resident as “Doe.”

The opinion addressed three motions filed by Meranelli: a motion under Federal Rule of Civil Procedure 12(f) to strike Pruette’s defense that the complaint failed to state a claim; a motion to require defense counsel’s contact information to be added to the facility’s privileged call list; and an amended motion to compel discovery.

Motion to Strike

Rule 12(f) allows a court to remove an insufficient defense or other improper material from a pleading. The court explained that motions to strike are generally disfavored and that removing Pruette’s defense would serve no practical purpose. The court therefore recommended that Meranelli’s motion to strike be denied. This was a recommendation, not a final district-court order in the text provided.

Motion to Compel Contact Information

Meranelli asked the court to require defense counsel to add their contact information to the Minnesota Sex Offender Program’s privileged call list so she could communicate with counsel through an unrecorded line. The court described the list as an exception to the facility’s usual recording and review of calls, and found that residents were not legally entitled to use that privilege to communicate with opposing counsel. The court also noted that Meranelli had been able to meet and confer with defense counsel. It denied this motion.

Discovery Motion

Under Federal Rule of Civil Procedure 26, discovery must concern nonprivileged information relevant to a claim or defense and proportionate to the needs of the case. The court found that Pruette had properly responded or objected to most of Meranelli’s requests.

The court found no deficiency in Pruette’s responses to Meranelli’s first discovery set. It also declined to require broad discovery about other Minnesota Sex Offender Program residents who were not connected to the allegations in the complaint. The court found that several requests were irrelevant, overly broad, vague, disproportionate, or sought legal conclusions. It likewise declined to require additional responses concerning uncontested jurisdiction and venue, Pruette’s affirmative defenses, and several requests for admissions.

The court granted in part the amended discovery motion as to three requests:

Discovery Set III, Document Request 7

Pruette was required to provide records sufficient to identify any other Minnesota Sex Offender Program resident who was granted or denied permission to possess a transparent lace cover-up in 2023, and to state whether permission was granted or denied.

Discovery Set VI, Document Request 2

Pruette was required to provide records sufficient to identify any Minnesota Sex Offender Program employee who processed the transparent lace cover-up described in the complaint.

Discovery Set VI, Document Request 1

To the extent Pruette’s answers to Meranelli’s requests for admission cited documents that had not already been produced, he was required to provide those documents.

The court’s order states that the amended motion to compel discovery was GRANTED IN PART as to those three requests and was otherwise DENIED.

Disposition and Review

The court denied the motion to compel counsel’s contact information. It granted in part and otherwise denied the amended motion to compel discovery. It recommended that the motion to strike be denied. The notice states that the report and recommendation was not a final order or judgment and was not directly appealable to the Eighth Circuit. It also states that a party could file written objections within 14 days after being served with the report and recommendation.