Canada v. State of Minnesota

CourtDistrict Court, D. Minnesota
DecidedOctober 26, 2023
Docket0:23-cv-02704
StatusUnknown

This text of Canada v. State of Minnesota (Canada v. State of Minnesota) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Canada v. State of Minnesota, (mnd 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA SHAWN CANADA, Civil No. 23-2704 (JRT/JFD) Petitioner,

v. ORDER AFFIRMING MAGISTRATE STATE OF MINNESOTA, et al., JUDGE’S DENIAL OF PLAINTIFF’S APPLICATION TO PROCEED IN FORMA Respondents. PAUPERIS

Shawn Canada, OID #233817, Minnesota Correctional Facility - Rush City, 7600 525th Street, Rush City, MN 55069, pro se Petitioner.

Plaintiff Shawn Canada, who is incarcerated, initiated this action against the State of Minnesota and various prison officials and staff (“Defendants”), asserting that they violated his civil rights. Magistrate Judge John F. Docherty issued an Order denying Canada’s application to proceed in forma pauperis (“IFP”) because Canada has accrued “three strikes” within the meaning of the Prison Litigation Reform Act of 1996 (“PLRA”). Canada appeals the Magistrate Judge’s Order, arguing that the imminent-danger-of- serious-physical-injury exception (“imminent danger exception”) to the “three strikes” rule applies under 28 U.S.C. § 1915(g) because he is in imminent danger of serious physical injury. Because Canada has accrued three strikes and has not shown imminent danger, the Court will deny Canada’s appeal, affirm the Magistrate Judge’s Order, and require Canada to pay the full filing fee within the time permitted by this Order, or his case will be dismissed without prejudice for failure to prosecute.

BACKGROUND Canada filed a complaint against various prison officials alleging violations of his civil rights under 42 U.S.C. § 1983 and the Fourteenth Amendment of the U.S.

Constitution. (See generally Compl., Sept. 1, 2023, Docket No. 1.)1 In his 186-page complaint, Canada argues that Defendants violated his constitutional rights by withholding information concerning Canada’s mental health from the Court and forcing Canada to lose over 25 jobs. (See id. at 25–26.) Canada seeks various money damages to

remedy alleged extension of his incarceration, previous arrests, various housing issues, loss of unemployment, loss of food stamps, and other harms. (See id. at 24, 50–57.) Canada applied to proceed IFP in this action. (Appl. to Proceed Without Prepaying Fees

or Costs, Sept. 1, 2023, Docket No. 2.) Upon reviewing Canada’s IFP application, the Magistrate Judge found that Canada is a prisoner subject to the PLRA, which places certain restrictions on his ability to obtain IFP status. (Order Den. Appl. (“Order”), at 1, Sept. 6, 2023, Docket No. 3.) Specifically,

the Magistrate Judge determined that Canada has already filed three actions in the District of Minnesota that were dismissed and qualify as “strikes” under the PLRA. (Order

1 All citations to the record are to Civil No. 23-2704 unless otherwise indicated. at 2; see also Civil No. 21-2388, Order Den. Appl., at 2, November 2, 2021, Docket No. 4.) The Magistrate Judge concluded that Canada has not established imminent danger of

serious physical injury, so the imminent danger exception under § 1915(g) does not apply. (Order at 2.) Accordingly, the Magistrate Judge found that § 1915(g) bars Canada from proceeding IFP in this litigation and denied his application on that basis. (Id.) Canada now appeals the Magistrate Judge’s denial of his IFP application. (Pl.’s Appeal, Oct. 2, 2023,

Docket No. 6.)

DISCUSSION I. STANDARD OF REVIEW

“The standard of review that is applicable to an appeal of a Magistrate Judge’s order on nondispositive pretrial matters is extremely deferential.” Shukh v. Seagate Tech., LLC, 295 F.R.D. 228, 235 (D. Minn. 2013); Roble v. Celestica Corp., 627 F. Supp. 2d 1008, 1014 (D. Minn. 2007). The Court will reverse such an order only if it is “clearly

erroneous or contrary to law.” 28 U.S.C. § 636(b)(1)(A); Fed. R. Civ. P. 72(a); D. Minn. LR 72.2(a)(3)(A). For an order to be clearly erroneous, the district court must be “left with the definite and firm conviction that a mistake has been committed.” Lisdahl v. Mayo Found., 633 F.3d 712, 717 (8th Cir. 2011) (citations omitted). “[T]he district court has

inherent power to review the final decision of its magistrates.” Bruno v. Hamilton, 521 F.2d 114, 116 (8th Cir. 1975). A document filed by a pro se litigant is to be liberally construed and must be held to a less stringent standard than formal pleadings drafted by lawyers. Erickson v. Pardus,

551 U.S. 89, 94 (2007). However, “pro se litigants are not excused from failing to comply with substantive and procedural law.” Burgs v. Sissel, 745 F.2d 526, 528 (8th Cir. 1984). II. IFP APPLICATION An incarcerated person who is unable to pay the filing fee for a civil action in

federal court may apply for IFP status. See 28 U.S.C. § 1915(b). IFP status does not mean that an incarcerated person is entitled to a full waiver of the filing fee. Id. § 1915(b)(1). Instead, IFP status merely permits an incarcerated person to pay the full filing fee in installments over a specified period. Id. § 1915(b)(2). A Magistrate Judge’s denial of an

IFP application is a nondispositive matter that is reviewed only for clear error. See, e.g., Perry v. Bos. Sci. Fam., No. 13-733, 2013 WL 6328760, at *2 (D. Minn. Dec. 5, 2013). The PLRA includes a “three strikes” provision that places restrictions on an incarcerated person’s ability to obtain IFP status.2 Specifically, the PLRA provides that an

2 The provision states,

In no event shall a prisoner bring a civil action or appeal a judgment in a civil action or proceeding under this section if the prisoner has, on 3 or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger of serious physical injury.

28 U.S.C. § 1915(g) (emphasis added). incarcerated person who has, on three or more occasions, brought an action in federal court that was dismissed because it was “frivolous, malicious, or fail[ed] to state a claim

upon which relief may be granted” is not entitled to IFP status. 28 U.S.C. § 1915(g). The only exception is if the incarcerated person is “under imminent danger of serious physical injury.” Id. The Eighth Circuit has held that the PLRA’s imminent danger exception only applies

if the requisite danger exists at the time that the complaint is filed, not when the alleged wrongdoing occurred. Martin v. Shelton, 319 F.3d 1048, 1050 (8th Cir. 2003). Moreover, a mere “general assertion” of imminent danger of serious physical injury is insufficient to

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Related

Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Lisdahl v. Mayo Foundation
633 F.3d 712 (Eighth Circuit, 2011)
Dorothy Bruno v. Hon. Calvin K. Hamilton
521 F.2d 114 (Eighth Circuit, 1975)
Roble v. Celestica Corp.
627 F. Supp. 2d 1008 (D. Minnesota, 2007)
Shukh v. Seagate Technology, LLC
295 F.R.D. 228 (D. Minnesota, 2013)
Burgs v. Sissel
745 F.2d 526 (Eighth Circuit, 1984)

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