Wright v. Mahowald et al

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Antonio Dupree Wright,
Plaintiff,
v.
Ramsey County, Minnesota; City of Saint
Paul Mayor, Melvin Carter; Saint Paul Po-
lice Department Chief; Ramsey County
District Court Chief; Ramsey County Dis-
trict Attorney, John J. Choi; Ramsey
County District Court Administrator; Ram-
sey County Sherriff; Sgt. Soren Mahowald;
Mark Reding; Derek Fitch; Richard
Bertholf; Elena L. Ostby; Governor Tim
Walz; Jane Doe 1, 2, 3; John Doe 1, 2, 3;
Amongst Others,
Defendants.
Case No. 25-CV-2502 (JRT/DLM)
REPORT AND RECOMMENDATION
This matter is before the Court on Plaintiff Antonio Dupree Wright’s amended
complaint (Docs. 51, 54 (collectively, the “Amended Complaint”)).1 For the following
reasons, the Court dismisses much of this action, but allows certain claims to proceed
against certain Defendants.2
1 Mr. Wright submitted Docs. 51 and 54 separately, but for present purposes the Court
construes them together as the operative “Amended Complaint.” Because the filings are
not consecutively paginated and their paragraph numbering does not align, the Court cites
the page numbers assigned by this District’s CM/ECF system (e.g., “Doc. 51 at __”).
2 By separate order, the Court will initiate service on certain Defendants named in the
Amended Complaint who have not already been served with process in this action.
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BACKGROUND
Accepting the Amended Complaint’s well-pleaded allegations as true, the relevant
facts are as follows. On September 4, 2022, a mass shooting occurred at a “drug house” on
Case Avenue in Saint Paul (within Ramsey County). (Doc. 51 at 3.) Six people were shot;
three were killed. (See id.) One surviving victim initially told Saint Paul police that the
shooter was a drug dealer known as “D” or “Figg,” to whom the victim owed money. (Id.)
This person “was suspected to be” Mr. Wright. The witness later recanted his identification
both before and during trial. (Id.) Witnesses’ physical description of the shooter (a man
with dreadlocks who arrived on a scooter, leaving a tan Glock handgun at the scene)
allegedly did not match Mr. Wright. (See id. at 3, 6.) Evidence later emerged that Mr.
Wright was in Chicago, Illinois, on the night of September 4, 2022. (See id. at 4, 6.) A Saint
Paul police forensic-video technician, Defendant Richard Bertholf, retrieved surveillance
video from Mr. Wright’s mother’s residence that ostensibly corroborated this alibi. (See id.
at 4.) Despite this exculpatory evidence and the lack of forensic evidence tying Mr. Wright
to the crime, authorities proceeded to charge him with multiple counts of homicide and
assault in Ramsey County Case No. 62-CR-22-5116. (See id. at 2, 4.3)
3 As of this Report and Recommendation, the Court has been unable to access records for
No. 62-CR-22-5116 on the Minnesota Judicial Branch’s Minnesota Court Records Online
system. However, apart from No. 62-CR-22-5116, Mr. Wright was also prosecuted in No.
62-CR-22-5111, where he was charged with various counts based on conduct on September
2, 2022. (See Compl. 1–2, State v. Wright, No. 62-CR-22-5111 (Minn. Dist. Ct. Sept. 7,
2022).) A jury convicted Mr. Wright on several counts in December 2023, he was sentenced
to 314 months’ imprisonment. (See Order and Warrant of Commitment 2–3, State v. Wright,
No. 62-CR-22-5111 (Minn. Dist. Ct. Jan. 30, 2024).) Mr. Wright is currently serving this
sentence.
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Mr. Wright alleges that Defendant Mark Reding, a Saint Paul police sergeant, swore
out a probable-cause affidavit on or about September 7, 2022, leading to Wright’s arrest
and prosecution. (See id. at 3.) Defendant Derek Fitch, an assistant Ramsey County
Attorney, allegedly worked in tandem with Reding to initiate and pursue the charges. (See
id. at 3–4; Doc. 54 at 3.) Mr. Wright alleges that Reding, Fitch, and another investigator,
Defendant Soren Mahowald (also a Saint Paul police sergeant), conspired to fabricate and
withhold evidence in order to implicate Mr. Wright. (See, e.g., Doc. 51 at 4, 7; Doc. 54 at
2–3.) Mr. Wright claims these Defendants (and people under their direction) “tampered
with evidence, lied under oath, falsified documents, and/or engaged in other . . . official
misconduct” to manufacture probable cause and wrongfully prolong his prosecution. (Doc.
54 at 3.) Mr. Wright contends that the police and prosecutors knew early on that an
eyewitness’s identification was unreliable (as the witness was under the influence of drugs
and later recanted), and that they possessed video and phone evidence pointing to Mr.
Wright’s innocence. Yet they pressed charges and took the case to trial “maliciously.” (See
Doc. 51 at 3–6; Doc. 54 at 3.) Mr. Wright asserts this was not a good-faith mistake. He
alleges the officials were driven by “implicit racial bias” and a desire to find a scapegoat,
leading them to target Mr. Wright (an out-of-state Black man) notwithstanding
contradictory evidence. (Doc. 51 at 7–8.) He cites historical and statistical information
about racial disparities in the justice system, alleging that Defendants’ actions reflected “a
custom of racial bias” in Ramsey County and Saint Paul that infected his case. (See, e.g.,
id. at 7–8, 13; Doc. 54 at 1.)
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Mr. Wright was detained throughout the criminal proceedings and alleges multiple
violations of his rights. First, he alleges a state trial judge, Defendant Elena Ostby, imposed
an excessive bail amount far beyond what was warranted, effectively ensuring Mr. Wright’s
pretrial incarceration. (See Doc. 51 at 4; Doc. 54 at 3.) Mr. Wright, with no significant ties
to Minnesota (he refers to himself as an Illinois citizen), alleges that his bail was set at an
unaffordable level, which he claims violated the Eighth Amendment and the Minnesota
Constitution’s prohibitions on excessive bail. (See Doc. 51 at 3–4; Doc. 54 at 2.) He
attributes this decision to the same discriminatory custom described above, asserting that
Judge Ostby “impos[ed] an excessive bail against Plaintiff motivated by [racial and role-
based bias].” (Doc. 54 at 2.) Mr. Wright further alleges that Defendants Choi and Fitch
sought this unreasonably high bail. He also alleges that the “Ramsey County District Court
Chief Judge” tacitly approved such practices. (See Doc. 51 at 11; Doc. 54 at 2–3.)
Second, Mr. Wright claims he was denied necessary medical care while detained at
the Ramsey County Jail (“RCJ”). Specifically, Mr. Wright indicates that he suffers from
multiple sclerosis (“M.S.”), a serious degenerative condition. (See Doc. 51 at 6; Doc. 54 at
3.) He alleges that during pretrial detention, jail medical staff (Defendants “Jane Doe 1, 2,
3” and “John Doe 1, 2, 3,” described as jail medical providers) failed to provide needed
treatment for his M.S. (See Doc. 51 at 12; Doc. 54 at 3.) Despite Mr. Wright’s requests for
care, his condition allegedly went untreated, causing severe health deterioration. (See Doc.
51 at 6; Doc. 54 at 3.) Mr. Wright says that he experienced significant weight loss, impaired
vision, chronic pain, and other complications as a result of RCJ staff’s deliberate
indifference to his medical needs. (See Doc. 51 at 6; Doc. 54 at 3–4.) He characterizes this
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neglect as torture, which put him at risk of losing his life. (Doc. 54 at 3.) Mr. Wright
contends that he was in the custody of Defendant Ramsey County Sheriff during this
period, and suggests that both the Sheriff’s Office and Ramsey County are responsible for
these medical issues. (See Doc. 51 at 3, 12.)
Third, Mr. Wright alleges various ancillary harms stemming from his wrongful
incarceration and prosecution. He says that he lost personal property; suffered severe
emotional trauma, depression, and reputational damage from being publicly accused as a
murderer; lost employment opportunities; and even suffered the end of a romantic
relationship because of the charges. (See id. at 6–7.) The Amended Complaint also alleges
that Mr. Wright suffered “[d]efamation” and “[r]eputational [h]arm” based on his false
imprisonment and prosecution. (Id. at 13; Doc. 54 at 4.4)
Ultimately, Mr. Wright stood trial in 2023 and was acquitted on all counts. (See, e.g.,
Doc. 51 at 2, 5.) He maintains that the prosecution was baseless from the start and pursued
with malice and reckless disregard for his rights. (See id. at 3; Doc 54 at 2–3.) He claims
that numerous individual Defendants—police officials (Mahowald, Reding, Bertholf); the
prosecutors (Fitch and Choi); and judges and other officials—violated his federal
constitutional rights through their actions (or inactions). (See Doc. 51 at 14; Doc. 54 at 1–
3.) He further asserts that various municipal and government entities (Ramsey County, the
4 The Amended Complaint does not identify any specific defamatory statements or who
made them. It instead refers only to generic Doe defendants (who are presumably distinct
from the Doe defendants associated with Mr. Wright’s medical-care claims). (See Doc. 51
at 13; Doc. 54 at 4.)
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City of Saint Paul, and the State of Minnesota) are also liable because wrongful acts were
done under official authority and allegedly reflect institutional policies or customs. (See
Doc. 51 at 7–10, 13.) Mr. Wright states that all Defendants acted “in concert” and “aid[ed]
and abet[ed]” each other as part of a broad conspiracy against him. (Doc. 51 at 14; Doc. 54
at 3.)
The Amended Complaint purports to bring ten numbered counts, most of which are
pleaded under 42 U.S.C. § 1983 together with ostensibly parallel state-law theories. (See
Doc. 51 at 11–13.) Count 1 alleges malicious prosecution under § 1983; it also expressly
“includes” a parallel “Common Law Malicious Prosecution claim” labeled “Count 1.5.”
(Id. at 11.) Count 2 alleges excessive bail under § 1983 and purports to include a “Common
Law Abuse of Process” claim as “Count 2.5.” (See id.) Count 3 asserts an equal-protection
violation and refers to what Mr. Wright calls a “State Conferred Rights claim.” (Id.) Count
4 pleads a broad § 1983 due-process claim, with another “Abuse of Process claim” referred
to as Count 4.5. (Id.)
Counts 5 through 7 bundle several federal and Minnesota civil-rights statutes. Count
5 again invokes § 1983, but this time seemingly using it to bring claims under the Violent
Crime Control and Law Enforcement Act of 1994,5 the Omnibus Crime Control and Safe
5 Pub. L. No. 103-322, 108 Stat. 1796.
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Streets Act of 1968,6 and Title VI of the 1964 Civil Rights Act.7 (See id. at 12.) Count 5
also suggests a parallel claim under the Minnesota Human Rights Act.8 (See id.) Count 6
appears to cite the same statutes, but then also refers, more specifically, to 42 U.S.C. §§
2000d, 14141, and 3789d. (See id.) Count 7 asserts a § 1983 denial-of-medical-care claim,
and here Mr. Wright explicitly appends claims of common-law negligence and gross
negligence in a theory termed “Count 7.5.” (Id.)
The remaining counts are framed as purely state-law torts. (See id. at 12–13.) Count
8 alleges intentional infliction of emotional distress; Count 9 claims tortious interference
with prospective economic advantage; and Count 10 asserts defamation and “reputational
harm.” (Id.)
For relief, Mr. Wright primarily seeks money damages for what he characterizes as
wrongful detention and prosecution, including both economic and noneconomic losses.
(See id. at 7; Doc. 54 at 4.) He asks the Court to award compensatory and punitive damages:
the amount is hard to read, but Mr. Wright apparently seeks $25,900,000.00, to be paid
“separately and collectively” by all Defendants. (Doc. 54 at 4.) He also asks for
“[d]eclaratory relief finding Defendant(s) actions [were] unconstitutional and unlawful.”
(Id.)
6 Pub. L. No. 90-351, 82 Stat. 197.
7 Pub. L. No. 88-352, §§ 601–605, 78 Stat. 241, 252–53 (codified as amended at 42 U.S.C.
§§ 2000d–2000d-7).
8 Minn. Stat. §§ 363A.01–.50.
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ANALYSIS
I. Standards of Review
Rather than pay this action’s filing fee, Mr. Wright submitted an application to
proceed in forma pauperis (“IFP”), which this Court granted. (See Docs. 2, 5.) Under the
federal statute governing IFP proceedings, “[n]otwithstanding any filing fee, or any portion
thereof, that may have been paid, the court shall dismiss [an IFP matter] at any time if the
court determines that . . . the action . . . fails to state a claim on which relief may be granted;
or . . . seeks monetary relief against a defendant who is immune from such relief.” 28
U.S.C. § 1915(e)(2).9
When determining if a complaint states a claim on which a court may grant relief, a
district court accepts the complaint’s factual allegations as true and draws all reasonable
inferences in the plaintiff’s favor. See, e.g., Varga v. U.S. Bank Nat. Ass’n, 764 F.3d 833,
836 (8th Cir. 2014) (citing Loftness Specialized Farm Equip., Inc. v. Twiestmeyer, 742 F.3d
845, 854 (8th Cir. 2014)). A complaint’s factual allegations need not be detailed, but they
must “raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550
U.S. 544, 555 (2007) (citing authorities). A complaint must “‘state a claim to relief that is
plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550
U.S. at 570). District-court consideration of whether a pleading states a claim is “context-
9 Furthermore, under 28 U.S.C. § 1915A, the Court must screen any civil complaint brought
by a prisoner against governmental entities or officials, and “identify cognizable claims or
dismiss the complaint, or any portion of the complaint,” if it is frivolous, malicious, fails
to state a claim, or seeks monetary relief from an immune defendant. 28 U.S.C. § 1915A(b).
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specific”; a court must “draw on its judicial experience and common sense.” Id. at 679; see
also, e.g., Zink v. Lombardi, 783 F.3d 1089, 1098 (8th Cir. 2015) (en banc) (making same
points (quoting Magee v. Trs. of Hamline Univ., 747 F.3d 532, 535 (8th Cir. 2014)) (cleaned
up)). Courts should construe pro se complaints “‘liberally,’” but such pleadings must still
allege enough facts to support the claims advanced. Sandknop v. Mo. Dep’t of Corrs., 932
F.3d 739, 742 (8th Cir. 2019) (quoting Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004)).
Furthermore, under Federal Rule of Civil Procedure 12(h)(3), “[i]f the court
determines at any time that it lacks subject-matter jurisdiction [over an action], the court
must dismiss” the matter.
II. Immunities
A. Distinction between official-capacity and individual-capacity claims
Mr. Wright purports to sue each individual Defendant in both his or her official and
individual capacities. In assessing certain immunities bearing on this action, the Court will
refer to the distinction between individual-capacity claims and official-capacity claims
against public officials.
On one hand, courts treat an official-capacity claim against a public official as a
claim against the official’s governmental employer. See, e.g., Will v. Mich. Dep’t of State
Police, 491 U.S. 58, 71 (1989) (citing cases); Brewington v. Keener, 902 F.3d 796, 800 (8th
Cir. 2018) (citing Liebe v. Norton, 157 F.3d 574, 578 (8th Cir. 1998)). Thus, Mr. Wright’s
official-capacity claims against the “Saint Paul Police Department Chief,” Carter,
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Mahowald, Reding, and Bertholf are, in effect, claims against the City of Saint Paul.10 A
municipality or county can be liable under § 1983 only if (generally speaking) a municipal
policy or custom caused the constitutional violation; municipalities and counties cannot be
held vicariously liable for their employees’ wrongful acts. See, e.g., Bd. of Cnty. Comm’rs
of Bryan Cnty. v. Brown, 520 U.S. 397, 403–04 (1997) (citing cases); Hall v. Higgins, 77
F.4th 1171, 1178 (8th Cir. 2023) (same).
On the other hand, suits against an official in his or her individual capacity seek to
hold that official personally liable for actions, taken under color of state law, that violated
the plaintiff’s rights. See, e.g., Hafer v. Melo, 502 U.S. 21, 25 (1991) (quoting Kentucky v.
Graham, 473 U.S. 159, 166 (1985)); Handt v. Lynch, 681 F.3d 939, 943 (8th Cir. 2012)
(quoting and citing cases, including Graham). To state an individual-capacity claim under
§ 1983, a plaintiff must allege that the relevant official, through his or her own individual
actions, violated the Constitution; an official will not be liable under § 1983 simply because
of his or her supervisory role. See, e.g., Iqbal, 556 U.S. at 676; Marsh v. Phelps Cnty., 902
F.3d 745, 754 (8th Cir. 2018) (quoting Iqbal). Furthermore, individual-capacity claims may
be subject to personal immunity defenses. See, e.g., Hafer, 502 U.S. at 25 (citing Graham,
473 U.S. at 166–67).
10 For completeness, Mr. Wright’s official-capacity claims against “Ramsey County
District Court Chief Judge,” “Ramsey County District Court Administrator,” Judge Ostby,
and Governor Walz are claims against the State of Minnesota; his official-capacity claims
against Choi, Fitch, and the “Ramsey County Sheriff” are claims against Ramsey County.
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B. State sovereign immunity
As explained above, Mr. Wright’s official-capacity claims against the “Ramsey
County District Court Chief Judge,” the “Ramsey County District Court Administrator,”
Judge Ostby, and Governor Walz are claims against the State of Minnesota and its judicial
branch. The Eleventh Amendment bars private suits in federal court against a State (or “arm
of the State”), absent the State’s unequivocal waiver of immunity or a valid abrogation by
Congress. See, e.g., Seminole Tribe of Fla. v. Florida, 517 U.S. 44, 54–55 (1996) (citing
and quoting cases); EEE Mins., LLC v. North Dakota, 81 F.4th 809, 815 (8th Cir. 2023)
(citing Va. Off. for Prot. & Advoc. v. Stewart, 563 U.S. 247, 253–54 (2011)). Nothing in the
Amended Complaint suggests that Minnesota has waived Eleventh Amendment immunity
for the state-law tort and statutory claims Mr. Wright asserts here, or that Congress has
abrogated Minnesota’s immunity for those claims.
Sovereign immunity is especially clear for Mr. Wright’s state-law claims against
these state officials. Federal courts lack jurisdiction to order state officials to comply with
state law. The Eleventh Amendment therefore bars claims (for any sort of relief) that would
require assessing alleged violations of the Minnesota Constitution (or other Minnesota-law
duties) by state officers sued in their official capacities. See, e.g., Pennhurst State Sch. &
Hosp. v. Halderman, 465 U.S. 89, 106 (1984); Smith v. Reynolds, 139 F.4th 631, 637 (8th
Cir. 2025) (citing Pennhurst). Mr. Wright’s official-capacity damages claims under 42
U.S.C. § 1983 are also barred because a State (and a state official sued in his or her official
capacity) is not a “person” subject to § 1983 damages liability. See, e.g., Will, 491 U.S. at
70–71; Calzone v. Hawley, 866 F.3d 866, 872 (8th Cir. 2017) (citing Will).
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Ex parte Young also does not permit Mr. Wright’s official-capacity claims. That
doctrine allows suits against state officers for prospective injunctive relief to end an
ongoing violation of federal law. See, e.g., Idaho v. Coeur d’Alene Tribe of Idaho, 521 U.S.
261, 269–70 (1997) (discussing doctrine); Minn. Chapter of Associated Builders &
Contractors v. Ellison, 153 F.4th 695, 698 (8th Cir. 2025) (same (quoting Whole Woman’s
Health v. Jackson, 595 U.S. 30, 39 (2021)). Here, though, Mr. Wright seeks retrospective
relief: damages and declarations that Defendants’ past conduct violated his rights. Ex parte
Young does not allow retrospective declaratory relief. See, e.g., Green v. Mansour, 474 U.S.
64, 73 (1985); Smith, 139 F.4th at 635 (quoting cases).
The Court thus recommends dismissing all official-capacity claims against
Defendants “Ramsey County District Court Chief,” “Ramsey County District Court
Administrator,” Judge Ostby, and Governor Walz.
C. Judicial immunity
On the individual-capacity side, judges are absolutely immune from individual-
capacity suits arising out of their judicial acts, even if a plaintiff alleges the judge acted
erroneously or maliciously. See, e.g., Mireles v. Waco, 502 U.S. 9, 11 (1991) (per curiam)
(citing cases); Hamilton v. City of Hayti, 948 F.3d 921, 925 (8th Cir. 2020) (citing Stump v.
Sparkman, 435 U.S. 349, 355–56 (1978)). There are narrow exceptions: judicial immunity
does not apply if (1) the challenged conduct was nonjudicial (i.e., not taken in the judge’s
judicial capacity), or (2) the judge acted in the clear absence of all jurisdiction. See, e.g.,
Mireles, 502 U.S. at 11–12 (citing cases); Hamilton, 948 F.3d at 925 (quoting Mireles).
With respect to the Amended Complaint’s individual-capacity claims against “Ramsey
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County District Court Chief” and Judge Ostby, neither exception is plausibly implicated
here.
As to Judge Ostby, Mr. Wright’s claims target quintessential judicial functions:
presiding over a criminal case, setting bail, and making rulings in the course of the
prosecution. Those are paradigmatic “judicial acts” within the jurisdiction of a Minnesota
district judge. Even accepting Mr. Wright’s allegations that the bail decision and other
rulings were biased or wrongful, those allegations go to those acts’ propriety, not whether
they were nonjudicial or jurisdictionally void. The same principles bar any individual-
capacity claims against the “Ramsey County District Court Chief Judge.” Everything Mr.
Wright alleges concerns the conduct of adjudication and falls within no judicial-immunity
exception.11 Accordingly, the Court recommends dismissing any individual-capacity
claims against Judge Ostby or the “Ramsey County District Court Chief Judge.”
D. Prosecutorial immunity
Prosecutorial immunity bars Mr. Wright’s individual-capacity damages claims
against Defendants Choi and Fitch. Prosecutors are absolutely immune from civil damages
liability for conduct “‘intimately associated with the judicial phase of the criminal
process,’” including evaluating evidence, deciding to file (or maintain) charges, advocating
in court, and presenting the State’s case. Buckley v. Fitzsimmons, 509 U.S. 259, 269 (1993)
11 Indeed, Mr. Wright’s allegations against the “Chief Judge” appear to rest on a supervisory
theory, rather than the Chief Judge’s personal participation in any specific constitutional
violation. As noted above, however, § 1983 does not permit individual liability based solely
on a defendant’s status as a supervisor.
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(quoting Imbler v. Pachtman, 424 U.S. 409, 430 (1976)); see also, e.g., Stockley v. Joyce,
963 F.3d 809, 817 (8th Cir. 2020) (making same point (quoting Burns v. Reed, 500 U.S.
478, 486 (1991)). Immunity applies even if a plaintiff alleges that a prosecution was
malicious or otherwise dishonest. See, e.g., Imbler, 424 U.S. at 427–28; Stockley, 963 F.3d
at 818 (citing cases).
Mr. Wright’s claims against Fitch and Choi rest on their pursuit and maintenance of
his prosecution in No. 62-CR-22-5116, which are core “advocacy” functions protected by
prosecutorial immunity. The Eighth Circuit has recognized that even alleged misconduct
such as withholding exculpatory evidence or encouraging false testimony remains covered
when it occurs in a prosecutor’s role as an advocate preparing for and presenting the State’s
case. See, e.g., Reasonover v. St. Louis Cnty., 447 F.3d 569, 580 (8th Cir. 2006) (citing
Myers v. Morris, 810 F.2d 1437, 1446 (8th Cir. 1987)).12 The Court therefore recommends
dismissing Mr. Wright’s individual-capacity damages claims against Fitch and Choi.13
12 Myers was abrogated by the U.S. Supreme Court’s decision in Burns, but on other
grounds. See Burns, 500 U.S. at 483 n.2.
13 Mr. Wright also appears to seek declaratory relief against Choi and Fitch, and absolute
prosecutorial immunity does not apply to claims for declaratory relief. But any declaratory-
relief claims against these Defendants fail for other reasons. First, declaratory relief is not
an appropriate vehicle for obtaining a declaration that defendants violated the law in the
past where the challenged prosecution has ended and there is no ongoing legal relationship
to which the proposed prospective relief would apply. Cf. Green v. Mansour, 474 U.S. 64,
73–74 (1985) (finding declaratory relief inappropriate where it would be “a [declaration]
that [the State] violated federal law in the past” with no ongoing violation). Second, to the
extent any requested declaration would regulate Choi’s or Fitch’s future official conduct as
prosecutors, the claim is effectively official-capacity in nature. But Mr. Wright does not
plead a plausible ongoing federal-law violation that would make prospective declaratory
relief appropriate.
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E. Quasi-judicial immunity
As a final immunity issue at prescreening, the Amended Complaint names the
“Ramsey County District Court Administrator” as a defendant in his or her individual
capacity. Mr. Wright alleges that this person “fil[ed] and process[ed] malicious [cases] . . .
in association with . . . other conspirants” and thereby “abus[ed] the legal process.” (See
Doc. 54 at 2.) In other words, Mr. Wright faults a court administrator for accepting and
processing documents in Mr. Wright’s criminal case in No. 62-CR-22-5116. But such an
official is performing clerical and administrative duties for a court. Court clerks and
administrators share in judicial immunity for conduct that is “taken at the direction of a
judge, or taken according to court rules.” Hamilton, 948 F.3d at 928 (citing cases); see also,
e.g., Dyson v. Bartolomei, No. 25-CV-2296 (LMP/JFD), 2025 WL 3063336, at *6 (D.
Minn. Nov. 3, 2025) (citing cases, including Hamilton); Salgat v. Am. Arb. Ass’n, Inc., No.
A22-1599, 2023 WL 4067364, at *2 (Minn. Ct. App. June 20, 2023) (discussing analogous
state-law doctrine). The Court therefore recommends dismissing Mr. Wright’s individual-
capacity claims against the “Ramsey County District Court Administrator.”
The Court notes that the Amended Complaint also appears to assert state-law claims against
Choi and Fitch. But Minnesota law supplies its own prosecutorial-immunity doctrine that
protects prosecutors from civil liability for actions taken in the course of filing and
maintaining criminal charges. See, e.g., Stresemann v. Jesson, 868 N.W.2d 32, 34 (Minn.
2015) (discussing doctrine). The Court therefore recommends dismissing the Amended
Complaint’s state-law claims against Fitch and Choi, in addition to its federal-law claims.
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III. Pleading of Federal-Law Claims
A. Miscellaneous statutory claims
As noted above, the Amended Complaint raises numerous federal statutory claims
in addition to constitutional claims under 42 U.S.C. § 1983. The Court addresses these
statutes in turn.
First, Counts 5 and 6 point to the Violent Crime Control and Law Enforcement Act
of 1994 (“VCCLEA”), and Count 6 specifically refers to 42 U.S.C. § 14141, a statute that
was part of the VCCLEA and has since been moved to 34 U.S.C. § 12601. Section 12601(a)
makes it unlawful for any law-enforcement agency or agent to engage in a pattern or
practice of conduct that deprives persons of their constitutional rights. But § 12601(b)
shows that Congress vested enforcement of this provision with the U.S. Attorney General.
There is no private right of action under the statute. See, e.g., Edner v. Ottertail Cnty., No.
20-CV-2402 (NEB/LIB), 2021 WL 2792373, at *2 n.2 (D. Minn. Mar. 30, 2021) (quoting
Thompson v. Creve Coeur Police Dep’t, No. 19-CV-2138 (SNLJ), 2019 WL 3860073, at
*2 (E.D. Mo. Aug. 16, 2019)), R. and R. adopted, 2021 WL 2493806 (D. Minn. June 18,
2021).
Second, Counts 5 and 6 refer to the Omnibus Crime Control and Safe Streets Act
(“OCCSSA”), and Count 6 specifically cites 42 U.S.C. § 3789d, which is part of that bill
and has since been moved to 34 U.S.C. § 10228. Under § 10228(c)(1), “[n]o person in any
State shall on the ground of race, color, religion, national origin, or sex be excluded from
participation in, be denied the benefits of, or be subjected to discrimination under or denied
employment in connection with any programs or activity funded in whole or in part with
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funds made available under this chapter,” with the relevant act funding law-enforcement
and criminal-justice programs. And § 10228(c)(4) does indeed provide a private right of
action for relevant violations. But to bring such a claim in federal court, a plaintiff must
first exhaust administrative remedies. See 34 U.S.C. § 10228(c)(4)(A); Horde v. Elliot, No.
17-CV-800 (WMW/SER), 2018 WL 987683, at *14 (D. Minn. Jan. 9, 2018) (discussing
exhaustion requirement), R. and R. adopted, 2018 WL 985294 (D. Minn. Feb. 20, 2018).
There is no suggestion that Mr. Wright has done so here.
Finally, Counts 5 and 6 both list Title VI of the Civil Rights Act of 1964, and Count
6 refers to 42 U.S.C. § 2000d, which is part of Title VI. But any claims under § 2000d fail
for several reasons. First, § 2000d is enforceable through a private right of action only
against entities that receive certain federal financial assistance, not against individual
employees or officials, so no § 2000d claims can proceed against any individual
defendants. See, e.g., Null v. Entrepreneur Startup Bus. Dev., No. 23-CV-0702 (SRC), 2024
WL 551607, at *3 (E.D. Mo. Feb. 9, 2024) (collecting cases); Pruitt v. Anderson, No. 11-
CV-2143 (DSD/JJK), 2011 WL 6141084, at *3 (D. Minn. Dec. 9, 2011) (citing cases).
Second, even assuming some governmental entities named (e.g., the City of Saint Paul or
Ramsey County) receive federal funds, Mr. Wright alleges only, in a broad and conclusory
way, that “[a]ll defendants received some form of federal benefits,” without identifying a
specific federally funded “program or activity,” the relevant federal financial assistance, or
facts showing he was excluded from participation in, denied benefits of, or otherwise
subjected to discrimination under that funded program on the basis of race. Third, Title VI
requires proof (and at the pleading stage, plausible factual allegations) of intentional
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discrimination because of race, color, or national origin, and Mr. Wright alleges only
generalized claims of racial bias and disparities. The Amended Complaint does not provide
any concrete, nonconclusory facts tying any challenged conduct by Defendants to
intentional race-based decisionmaking.
The Court therefore recommends dismissing the Amended Complaint without
prejudice, for failure to state a claim, to the extent that Mr. Wright seeks to bring claims
under 34 U.S.C. § 12601, 34 U.S.C. § 10228, and 42 U.S.C. § 2000d.
B. Individual-capacity claims against Defendants Walz, Carter, “Saint Paul
Police Department Chief,” and the “Ramsey County Sheriff”
As discussed above, Mr. Wright purports to sue Defendants Walz, Carter, “Saint
Paul Police Department Chief,” and the “Ramsey County Sheriff” in their individual
capacities. For these defendants, the individual-capacity claims appear to rest solely on a
supervisory-liability theory. But again, § 1983 does not permit plaintiffs to sue supervisors
simply as supervisors: “each Government official, his or her title notwithstanding, is only
liable for his or her own misconduct.” Iqbal, 556 U.S. at 677. As discussed above,
supervisory liability instead requires personal involvement or a deliberately indifferent
failure to train or supervise. See, e.g., Jackson v. Nixon, 747 F.3d 537, 543 (8th Cir. 2014)
(citing cases).
The Amended Complaint alleges no specific facts that Walz, Carter, the “Saint Paul
Police Department Chief,” or the “Ramsey County Sheriff” participated in Mr. Wright’s
arrest, prosecution, detention, or medical care. Mr. Wright names Walz apparently because
he is “the highest ranking official in the State of Minnesota,” who thus ostensibly serves as
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“the overseer of all state employees.” (Doc. 51 at 14.) But this is precisely the sort of
supervisory-liability theory that cannot support an individual-capacity § 1983 claim.
As to Carter, there is no allegation that he knew of Mr. Wright’s case until after Mr.
Wright’s arrest became public. Nor is there any allegation that Carter directed the
investigation or encouraged any constitutional violations. Nothing here plausibly suggests
that Carter caused any alleged harms, so any individual-capacity claims against him fail.
Saint Paul’s police chief is apparently named simply because he leads the
department whose officers investigated and arrested Mr. Wright. But, as noted above, §
1983 does not make a police chief liable for subordinate officers’ acts. Mr. Wright does not
allege, for instance, that the chief was present, investigated, made decisions in the case, or
ordered (or knew of) any unconstitutional conduct. Mr. Wright also does not plausibly
allege a pattern of similar misconduct or any concrete failure of training or supervision.
Instead, he offers only conclusory assertions that the police chief was his employees’
“overseer,” which is insufficient. See, e.g., S.M. v. Krigbaum, 808 F.3d 335, 340–42 (8th
Cir. 2015) (explaining limited circumstances when supervisory liability can arise).
Finally, Mr. Wright’s allegations against Ramsey County’s sheriff focus on pretrial
detention and medical care, but the Amended Complaint does not allege that this individual
personally denied Mr. Wright care, knew of Mr. Wright’s needs, received complaints, or
had notice of a pattern of inmate medical neglect. The allegations therefore do not plausibly
plead liability by the sheriff.
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Given this discussion, the Court recommends dismissing any individual-capacity
claims against Walz, Carter, the “Saint Paul Police Department Chief,” and the “Ramsey
County Sheriff.”
C. Municipal liability
The Amended Complaint names Ramsey County and the City of Saint Paul as
Defendants. It also names various employees of both entities and sues them in their official
capacities. Because an official-capacity claim against a local-government employee
amounts to a claim against the employer itself, these official-capacity claims function as
claims against Ramsey County and the City of Saint Paul.
As noted above, a local government can be held liable under § 1983 only for its own
illegal acts; in other words, a city or county “may not be held liable under § 1983 solely
because it employs a tortfeasor.” Brown, 520 U.S. at 403; see also, e.g., Robbins v. City of
Des Moines, 984 F.3d 673, 681 (8th Cir. 2021) (making same point (quoting Atkinson v.
City of Mountain View, 709 F.3d 1201, 1214 (8th Cir. 2013)). Instead, a plaintiff must
allege that a municipal policy or custom of the relevant government was the “‘moving
force’” behind the constitutional violation. Brown, 520 U.S. at 400 (quoting Monell v. Dep’t
of Soc. Servs., 436 U.S. 658, 694 (1978)). This generally requires pleading an express
municipal policy; a widespread and persistent practice or custom; a decision or act of an
official with final policymaking authority; or a failure to train, supervise, or discipline
employees that amounts to an official policy of deliberate indifference to constitutional
rights. See, e.g., Connick v. Thompson, 563 U.S. 51, 61 (2011) (citing cases); Troupe v.
Young, 143 F.4th 955, 973–74 (8th Cir. 2025) (making similar points (quoting cases)).
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The Amended Complaint makes only a passing reference to a “patterned-practice”
of the City and County of “failure-to-remedy . . . racial bias wrongs.” (Doc. 51 at 13.) Mr.
Wright presumably contends that this practice resulted in his wrongful arrest and
prosecution. But the Amended Complaint does not identify any specific formal policy (e.g.,
a written ordinance, regulation, or departmental directive) that was unconstitutional. Nor
does it plead facts showing a well-settled custom of similar misconduct.14 Mr. Wright
essentially describes his own case, then attributes its flaws to broader institutional failings.
This is just the sort of pleading that does not pass muster. See Iqbal, 556 U.S. at 678
14 Mr. Wright devotes several pages of the Amended Complaint to sections entitled
“Custom(s),” “General Racial Disparities,” and “Criminal Racial Disparities.” (Doc. 51 at
7–10.) These passages cite social-science literature and assorted news reports on implicit
bias, traffic stops, wealth gaps, incarceration rates, and other purported disparities in
Ramsey County, Minnesota, and nationally. (See id.) But those materials do not plausibly
allege a Monell “custom” attributable to Saint Paul or Ramsey County. To allege an
unofficial custom, a plaintiff must allege (1) “‘[t]he existence of a continuing, widespread,
persistent pattern of unconstitutional misconduct by [the municipality’s] employees’”;
(2) “‘[d]eliberate indifference to or tacit authorization of such conduct by [the
municipality’s] policymaking officials after notice to the officials of that misconduct’”; and
(3) “[t]hat [the plaintiff] was injured by acts pursuant to [the municipality’s] custom.”
Mitchell v. Saint Louis Cnty., 160 F.4th 950, 964 (8th Cir. 2025) (citing cases) (cleaned up).
Even assuming that Mr. Wright’s recitation here covers the first element, he has not alleged
the second or third. Mr. Wright’s disparity discussion does not identify any specific Ramsey
County or Saint Paul policy or practice of misconduct like that alleged in his case (for
example) fabricating evidence, suppressing exculpatory evidence, initiating prosecutions
without probable cause, or otherwise engaging in sorts of misconduct alleged in his case.
He offers no concrete examples of other similar incidents, no facts showing municipal
policymakers were on notice of a pattern of such misconduct, and no nonconclusory
allegations supporting deliberate indifference. (See generally Doc. 51 at 7–10.) At most,
Mr. Wright asks the Court to infer a municipal custom from generalized societal data and
his own individual prosecution. That inference is too attenuated to satisfy Monell and the
Twombly/Iqbal plausibility requirements.
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(“Threadbare recitals of the elements of a cause of action, supported by mere conclusory
statements, do not suffice.” (citing Twombly, 550 U.S. at 555)).
The Court therefore recommends dismissing the Amended Complaint’s § 1983
claims against Ramsey County, the City of Saint Paul, and any County or City employees
sued in their official capacities.
D. Count 2 (excessive bail)
The Court next addresses certain Counts from the Amended Complaint, starting
with Count 2, which asserts that various Defendants inappropriately imposed excessive
bail on Mr. Wright in No. 62-CR-22-5116. This Count should be dismissed because every
Defendant that Mr. Wright names in Count 2 has already been dismissed above for
independent reasons (i.e., failure to allege any Monell claims, judicial and quasi-judicial
immunity, and prosecutorial immunity). As a result, there is no viable, nonimmune
Defendant who can be held personally responsible for the alleged constitutional violation.
For the same reason, the “abuse of process” claim Mr. Wright labels as Count 2.5
should be dismissed as well. For practical purposes, this claim appears to “piggyback” on
the same alleged wrongs: the court’s bail decision and the prosecutors’ advocacy
surrounding bail. If so, then (1) note that the only actors who plausibly “used process” in
that way are the judge and prosecutors, who are immune for that conduct, and (2) once
Count 2 is dismissed and all Count 2 defendants are out of the case, there is no standalone
factual basis left to sustain Count 2.5. The Court therefore recommends dismissing Count
2 (including Count 2.5) in its entirety.
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E. Count 3 (equal protection)
Count 3 asserts violations of the “Equal Protections Act,” which the Court construes
as referring to the Fourteenth Amendment’s Equal Protection Clause.15 Under that Clause,
“[n]o State shall . . . deny to any person within its jurisdiction the equal protection of the
laws.” U.S. Const. amend. XIV § 1. This clause “generally requires the government to treat
similarly situated people alike.” Klinger v. Dep’t of Corrs., 31 F.3d 727, 731 (8th Cir. 1994);
see also, e.g., Cherry v. MCF-Moose Lake, No. 22-CV-2012 (JRT/JFD), 2023 WL
1767832, at *5 (D. Minn. Jan. 17, 2023) (quoting Klinger), R. and R. adopted, 2023 WL
1767303 (D. Minn. Feb. 3, 2023).
Equal protection claims fall into two main categories. See, e.g., Engquist v. Ore.
Dep’t of Agr., 553 U.S. 591, 601–02 (2008). The first involves “governmental
classifications that ‘affect some groups of citizens differently than others.’” Id. (quoting
McGowan v. Maryland, 366 U.S. 420, 425 (1961)); see also, e.g., Gilmore v. Cnty. of
Douglas, 406 F.3d 935, 937 (8th Cir. 2005). In such cases, plaintiffs “allege that they have
been arbitrarily classified as members of an ‘identifiable group’” and then subjected to
unequal treatment.” Engquist, 553 U.S. at 601 (quoting Pers. Adm’r of Mass. v. Feeney,
15 It is unclear which Defendants Mr. Wright targets in Count 3. Mr. Wright first lists
specific defendants (Ramsey County, the “Saint Paul Police Department Chief,” Choi,
Carter, the “Ramsey County District Court Administrator,” and the “Ramsey County
Sheriff”). (Doc. 51 at 11.) But he then adds “(Against all defendants)), in both capacities.”
(Id.) The Court will assume for present purposes that Mr. Wright means to target all
Defendants; because he fails to state an equal-protection claim, the question is largely
academic.
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442 U.S. 256, 279 (1979)); see also, e.g., Jidoefor v. City of Minneapolis Police Dep’t,
No. 22-CV-1686 (KMM/TNL), 2023 WL 2823159, at *2 (D. Minn. Apr. 7, 2023).
To allege this sort of equal-protection claim, Mr. Wright must allege that (1) he was
treated differently than others who were similarly situated, and (2) the differential treatment
was the product of intentional discrimination based on group membership (here, race). See,
e.g., In re Kemp, 894 F.3d 900, 909–10 (8th Cir. 2018). At the pleading stage, a plaintiff
cannot simply assert discrimination in conclusory terms; a complaint must allege concrete
facts supporting a plausible inference of unequal treatment and discriminatory purpose.
See, e.g., Iqbal, 556 U.S. at 680–84.
Mr. Wright does not do that here. Although he broadly asserts “racial bias” and “role
effect bias” and cites generalized societal and systemwide disparities, he does not identify
any similarly situated non-Black individuals treated more favorably. Nor does he plead any
nonconclusory facts suggesting that any Defendant took certain actions because of Mr.
Wright’s race (as opposed to acting for other reasons, even if those reasons were mistaken
or unfair). As a result, the Amended Complaint fails to state this type of equal-protection
claim.
The second type of equal-protection claim is a “class of one” claim. Engquist, 553
U.S. at 601–02 (discussing Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000) (per
curiam)). In this sort of claim, “[w]hen those who appear similarly situated are nevertheless
treated differently, the Equal Protection Clause requires at least a rational reason for the
difference, to ensure that all persons subject to legislation or regulation are indeed being
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‘treated alike, under like circumstances and conditions.’” Id. (quoting Olech, 528 U.S. at
564).
To bring this type of claim, however, a plaintiff must allege that she is “‘similarly
situated to others who allegedly received preferential treatment.’” Sanimax USA, LLC v.
City of S. St. Paul, 95 F.4th 551, 564 (8th Cir. 2024) (quoting Robbins v. Becker, 794 F.3d
988, 996 (8th Cir. 2015)). Critically, a plaintiff must provide a “specific and detailed
account” of how others were favored. Higgins Electric, Inc. v. O’Fallon Fire Prot. Dist.,
813 F.3d 1124, 1129 (8th Cir. 2016) (quoting cases; cleaned up); see also Myers v.
Kleffman, No. 24-CV-3890 (JMB/LIB), 2024 WL 5301741, at *3 (D. Minn. Nov. 19, 2024)
(quoting Higgins Electric), R. and R. adopted, 2025 WL 48643 (D. Minn. Jan. 8, 2025).
This is a “significant hurdle,” as “the persons alleged to have been treated more favorably
must be identical or directly comparable to the plaintiff in all material respects”—and
without such allegations, “a class-of-one claim must fail.” Sanimax USA, 95 F.4th at 564
(quoting Robbins, 794 F.3d at 996 (quotation marks removed).
Here, the Amended Complaint provides no account of other individuals being
treated differently than him, much less any “specific and detailed account” of differential
treatment. The Court therefore recommends dismissing Count 3 of the Amended
Complaint.16
16 Count 3 includes what Mr. Wright describes as a “State Conferred Rights claim and
theory.” (Doc. 51 at 11.) The Court recommends dismissing this aspect of Count 3 because,
as pleaded, Mr. Wright does not identify the state-created right he invokes, the cause of
action that supplies a remedy, or the specific acts by Defendants that violated that right.
That is insufficient under Rule 8 of the Federal Rules of Civil Procedure; it does not give
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F. Count 4 (due process)
The Amended Complaint’s Count 4 appears to be a catch-all “Due Process Claim”
against “ALL DEFENDANTS,” without clarifying whether Mr. Wright asserts procedural
due process, substantive due process, or both. (Doc. 51 at 11.) Mr. Wright’s due-process
label appears to target the same core conduct alleged elsewhere (that is, his wrongful
detention and prosecution ostensibly driven by fabricated or suppressed evidence, plus
related mistreatment during the case), rather than any distinct deprivation of process
separate from his other federal-law claims.
On that reading, Count 4 fails. As for substantive due process, where a specific
constitutional provision “‘provides an explicit textual source of constitutional protection
against a particular sort of government behavior,’” courts should analyze the claim under
that provision, not under substantive due process. Cnty. of Sacramento v. Lewis, 523 U.S.
833, 842 (1998) (quoting Albright v. Oliver, 510 U.S. 266, 273 (1994) (plurality opinion));
Doe v. Aberdeen Sch. Dist., 42 F.4th 883, 893 (8th Cir. 2022) (making similar point (quoting
Soldal v. Cook Cnty., 506 U.S. 56, 70 (1992)). The Amended Complaint’s discussion of
liberty deprivations arising from criminal proceedings performed without probable cause
(and on allegedly false evidence) is presumably addressed (if at all) by the Fourth
Amendment’s framework governing unreasonable seizures and pretrial detention, not by
substantive due process. Similarly, and as discussed elsewhere in this Report and
Defendants fair notice of the claim’s legal basis or factual grounds. And to the extent this
“State Conferred Rights” theory is just a state-law analogue to Count 3’s federal equal-
protection theory, it fails for the same reasons: Mr. Wright pleads no nonconclusory facts
showing differential treatment of similarly situated persons or any discriminatory purpose.
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Recommendation, Mr. Wright’s arguments concerning alleged “excessive bail” fall under
the Eighth Amendment, and any alleged denial of medical care to a pretrial detainee is
addressed by the Fourteenth Amendment. Count 4 is therefore duplicative to the extent it
seeks to bring a substantive-due-process claim, and it should be dismissed on that basis.
As for procedural due process, on the other hand, Mr. Wright must allege facts
showing (1) a protected liberty or property interest and (2) a deprivation of that interest
without constitutionally adequate process. See, e.g., Schmidt v. Des Moines Pub. Schs., 655
F.3d 811, 817 (8th Cir. 2011) (quoting Gordon v. Hansen, 168 F.3d 1109, 1114 (8th Cir.
1999)); Bishop v. Swanson, No. 12-CV-0135 (KMM/DTS), 2023 WL 1786468, at *15 (D.
Minn. Jan. 24, 2023) (presenting similar elements (quoting Stevenson v. Blytheville Sch.
Dist. #5, 800 F.3d 955, 966 (8th Cir. 2015)), R. and R. adopted, 2023 WL 2523902 (D.
Minn. Mar. 15, 2023).
Mr. Wright’s precise theory is unclear, but may arise from Brady v. Maryland, 373
U.S. 83, 87 (1963). Under Brady, due process requires the prosecution to disclose evidence
favorable to the accused that is “material either to guilt or to punishment,” and suppression
of such evidence violates due process because it undermines a criminal proceeding’s
fairness. See, e.g., id. at 87–88. To advance this sort of claim, however, a plaintiff must
show that (1) the relevant evidence was favorable to the accused, (2) it was suppressed by
the State, and (3) the suppression was prejudicial. See, e.g., Strickler v. Greene, 527 U.S.
263, 281–82 (1999); United States v. Hayes, 44 F.4th 1134, 1141 (8th Cir. 2022) (quoting
Strickler). Under these standards, the Amended Complaint does not plausibly plead a
Brady-type claim. Mr. Wright does not identify what specific exculpatory or impeachment
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evidence was suppressed, who suppressed it, when it was withheld, or how the
nondisclosure caused material prejudice (particularly given his acquittal).
Any other due process theory—although none is evident from this Court’s review—
would also face significant obstacles. First, as discussed above, any request for damages
against the prosecutors for Brady-related conduct (or other sorts of due-process claims)
would be barred by absolute prosecutorial immunity because such disclosure decisions are
part of the prosecutor’s advocacy function in the judicial phase of the case. More
fundamentally, to the extent Mr. Wright’s procedural-due-process label is really suggesting
constitutional violations linked to his pretrial seizure and detention, courts typically
analyze such a theory under the more specific Fourth Amendment framework, not as a free-
standing procedural-due-process claim. See, e.g., Manuel v. City of Joliet, 580 U.S. 357,
367 (2017).
As a final point, Mr. Wright purports to include in Count 4 “an Abuse of Process
claim” that he refers to as “count 4.5.” (Doc. 51 at 11.) But “abuse of process” is a state-
law tort concept, not a freestanding federal constitutional claim subject to § 1983. If Mr.
Wright means by “abuse of process” just that authorities prosecuted him for improper
reasons, then the claim is redundant of the malicious-prosecution theory he raises in Count
1 (a count surviving for now against certain defendants). Because Count 4 and its purported
Count 4.5 do not plead any distinct, nonduplicative federal due-process violation (or any
cognizable federal “abuse of process” theory), the Court recommends dismissing Count 4
in its entirety.
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G. Count 7 (denial of medical care)
The Court also recommends dismissing Count 7, in which Mr. Wright alleges that
he was denied appropriate medical care at the RCJ. To state a claim for denial of medical
care under 42 U.S.C. § 1983, a pretrial detainee must allege (1) that he had an objectively
serious medical need, and (2) that the defendant’s conduct was deliberately indifferent to
that need. See, e.g., Troupe, 143 F.4th at 968 (quoting Jackson v. Buckman, 756 F.3d 1060,
1065 (8th Cir. 2014)).17 An objectively serious medical need is one “‘diagnosed by a
physician as requiring treatment’” or “‘so obvious that even a layperson would easily
recognize the need for a doctor’s attention.’” Id. at 969 (quoting Jackson, 756 F.3d at 1065).
Deliberate indifference exists when an official actually knew of the plaintiff’s serious
medical need and deliberately disregarded it, a standard going beyond negligence and
approximating criminal recklessness. See id. (quoting Jackson, 756 F.3d at 1065).
The Amended Complaint does not plead either element with sufficient specificity.
The pleading offers only vague, conclusory assertions that Mr. Wright’s health problems
“went untreated” during his detention. (Doc. 51 at 6.) For example, it states that Mr.
Wright’s M.S. was not treated while he was in the RCJ, and that he experienced dental
pain, a “[v]itamin D deficiency, [v]ision [i]mpairment, “[m]ental health deterioration,” and
other unspecified issues that were likewise left untreated. (Id.) But Mr. Wright provides no
factual detail about the severity of these conditions or the harm they caused. For instance,
17 A pretrial detainee’s right to medical care arises under the Fourteenth Amendment’s Due
Process Clause, but the analysis is the same as the Eighth Amendment standard applied to
convicted prisoners. See Troupe, 143 F.4th at 968 (citing Jackson, 756 F.3d at 1065).
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the Amended Complaint does not describe any acute symptoms, emergencies, or diagnoses
that would make his alleged conditions objectively serious under the above standard.
Count 7 also does not plead facts showing deliberate indifference by any particular
defendant. The Amended Complaint simply declares that Mr. Wright “sought treatment”
for his conditions but received none. (Id.) It does not identify who (if anyone) refused or
delayed care, on what dates, or what was communicated to jail staff about Mr. Wright’s
health issues. In fact, the only individual defendants named in Count 7 are unspecified Jane
Doe and John Doe officers or medical staff, and the pleading never pinpoints which Doe
knew of which condition or how they responded. Because the Amended Complaint offers
no factual content showing that any identified person knowingly ignored a serious health
risk, it does not meet the pleading requirements for a § 1983 denial-of-medical-care
claim.18
H. Claims under 42 U.S.C. § 1985(3)
The Amended Complaint does not plead a standalone count labeled “42 U.S.C.
§ 1985” (or identify any particular § 1985 subsection), but it repeatedly invokes § 1985 as
a basis for relief. In the opening “Introduction,” Mr. Wright states that this action is brought
18 Count 7 avers to a separate “Common Law Negligence, gross negligence claim and
theory,” labelled “count 7.5.” (Doc. 51 at 12.) Generally speaking, plaintiffs alleging
ordinary negligence claims under Minnesota state law must allege the familiar elements of
(1) a duty of care, (2) breach, (3) proximate causation, and (4) damages. See, e.g., Reichel
v. Wendland Utz, LTD, 11 N.W.3d 602, 612 (Minn. 2024) (quoting Gradjelick v. Hance,
646 N.W.2d 225, 234 (Minn. 2002). The Amended Complaint does not plausibly allege
any of those elements as to any identifiable actor, instead broadly accusing unnamed Doe
medical providers of “reckless disregard” and deliberate indifference.
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under § 1985 (among other provisions), and the “Counts” section repeatedly styles the
asserted causes of action as claims under “42 U.S.C. § 1983 and/or 1985.” (Doc. 51 at 2,
11–12.) The pleading also repeatedly uses the language of “conspiracy” or “concerted
action” to describe Defendants’ conduct. Given these references to § 1985, the Court briefly
addresses why the Amended Complaint fails to state a claim under that statute.
Of § 1985’s subsections, Mr. Wright presumably means to rely on § 1985(3), which
targets conspiracies motivated by racial or other class-based animus to deprive individuals
of equal protection of the laws or equal privileges and immunities. To state a claim under
§ 1985(3), a plaintiff must allege: (1) a conspiracy of two or more persons, (2) who
intended to deprive him of equal protection or equal privileges and immunities, (3) an act
in furtherance of the conspiracy, and (4) that he suffered an injury to his rights or property
or a deprivation of a right or privilege of a citizen. See, e.g., Federer v. Gephardt, 363 F.3d
754, 758 (8th Cir. 2004) (quoting Griffin v. Breckenridge, 403 U.S. 88, 102–03 (1971)).
Furthermore, a § 1985(3) claim requires allegations “of a class-based animus.” Id. (citing
Griffin, 403 U.S. at 102).
The Amended Complaint fails to meet these standards. First, Mr. Wright does not
plead any nonconclusory facts showing who allegedly agreed with whom, when and how
any agreement was formed, or what specific overt acts were taken in furtherance of a race-
based agreement to deprive Mr. Wright of equal protection. Instead, Wright largely just
repeats conclusory labels and generalized assertions about racial bias and disparities,
untethered to any concrete factual allegations suggesting a conspiratorial agreement. To the
extent the Complaint seeks to press a § 1985(3), then, the Court recommends denying it.
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I. Summary of federal-law analysis
Under the foregoing analysis, the Court concludes that the only federal-law claim
that remains in this action is that reflected in Count 1. The Court construes Count 1 as a
claim under 42 U.S.C. § 1983 raising concerns about Mr. Wright’s prosecution and the
investigative conduct leading to that prosecution. The Court further concludes that only
three Defendants should remain in this action: Defendants Mahowald, Reding, and
Bertholf. Because this case therefore continues to include at least one claim “arising under”
federal law, the Court will exercise supplemental jurisdiction over the Amended
Complaint’s state-law claims pursuant to 28 U.S.C. § 1367(a), as those claims arise from
the same nucleus of operative facts as the remaining federal claim.
IV. State-Law Claims
As a final aspect of screening the Amended Complaint, the Court briefly addresses
the remaining state-law claims. For now, the Court does not dismiss the state-law claims
implicit in Count 1, and it does not dismiss Mr. Wright’s intentional-infliction-of-
emotional-distress claim in Count 8.
Counts 9 and 10, however, ought to be dismissed. Count 9 asserts that Defendants
tortiously interfered with some prospective economic advantage of Mr. Wright’s. Under
Minnesota law, to recover for tortious interference with prospective economic advantage,
a plaintiff must prove that (1) he had a reasonable expectation of economic advantage; (2)
the defendant knew of that expectation; (3) the defendant intentionally interfered with it
through conduct that was independently tortious or violated a state or federal statute or
regulation; (4) absent the defendant’s wrongful act, it was reasonably probable that the
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plaintiff would have realized the expected economic advantage; and (5) the plaintiff
suffered damages. See, e.g., Gieseke ex rel. Diversified Water Diversion, Inc. v. IDCA, Inc.,
844 N.W.2d 210, 219 (Minn. 2014). Even assuming Mr. Wright’s claims about running a
food truck and engaging in music production are true (see Doc. 51 at 7), nothing in the
Amended Complaint suggests that any Defendants (much less the subset of Defendants
remaining in this action) knew of these plans or intentionally sought to interfere with them.
Count 10 asserts a defamation claim against unidentified Doe defendants. Setting
aside any problems with identifying these Does, the Amended Complaint fails to state a
defamation claim. To plead defamation, a plaintiff must allege that “‘the defendant made:
(a) a false and defamatory statement about the plaintiff; (b) in [an] unprivileged publication
to a third party; (c) that harmed the plaintiff’s reputation in the community.’” Maethner v.
Someplace Safe, Inc., 929 N.W.2d 868, 873 (Minn. 2019) (quoting Weinberger v.
Maplewood Review, 668 N.W.2d 667, 673 (Minn. 2003) (brackets in Maethner)). The
Amended Complaint does not identify any specific statements by any Defendant that could
satisfy the first element, nor does it allege any publication to a third party.
V. Next Steps
Based on the discussion above, this case will proceed on only a small part of the
Amended Complaint. Specifically, the only Counts remaining are Counts 1 and 8, and the
only Defendants remaining are Mahowald, Reding, and Bertholf (each sued in his
individual capacity). Mahowald has already been served with process, but Reding and
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Bertholf have not. The Court will therefore, in a separate order, initiate service on Reding
and Bertholf and end the stay previously entered in this action.19
RECOMMENDATION
Based upon the foregoing, and on all of the files, records, and proceedings herein,
IT IS HEREBY RECOMMENDED that:
1. Plaintiff Antonio Dupree Wright’s amended complaint (Docs. 51, 54
(“Amended Complaint”)) be DISMISSED WITHOUT
PREJUDICE, based on Eleventh Amendment immunity, to the
extent it brings official-capacity claims against Defendants “Ramsey
County District Court Chief Judge,” “Ramsey County District Court
Administrator,” Elena Ostby, and Tim Walz.
2. The Amended Complaint be DISMISSED WITH PREJUDICE,
based on judicial immunity, to the extent it brings individual-capacity
claims against Defendants “Ramsey County District Court Chief
Judge” and Elena Ostby.
3. The Amended Complaint be DISMISSED WITH PREJUDICE, due
to prosecutorial immunity, to the extent it brings individual-capacity
claims against Defendants John J. Choi and Derek Fitch.
4. The Amended Complaint be DISMISSED WITH PREJUDICE, due
to quasi-judicial immunity, to the extent it brings individual-capacity
claims against “Ramsey County District Court Administrator.”
5. The Amended Complaint be DISMISSED WITHOUT
PREJUDICE, for failure to state a claim, to the extent it brings the
following claims:
a. Claims under the Violent Crime Control and Law Enforcement
Act of 1994 (i.e., 34 U.S.C. § 12601), the Omnibus Crime
Control and Safe Streets Act of 1968 (i.e., 34 U.S.C. § 10228),
and Title VI of the Civil Rights Act of 1964 (i.e., 42 U.S.C.
§ 2000d), as laid out in Counts 5 and 6;
19 Defendants should note that the discussion in this Report and Recommendation is
without prejudice to their answering or otherwise responding to the Amended Complaint
in any manner permitted by the Federal Rules of Civil Procedure.
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b. Individual-capacity claims against Defendants Tim Walz,
Melvin Carter, the “Saint Paul Police Department Chief,” and
the “Ramsey County Sheriff”;
c. Official-capacity claims under 42 U.S.C. § 1983 claims against
Defendants Ramsey County, the City of Saint Paul, and any
County or City employees (as sued in their official capacities);
d. Counts 2, 3, 4, and 7 (including, as discussed above, any
subsidiary subclaims that Mr. Wright offers within those
claims).
e. Claims under 42 U.S.C. § 1985(3).
f. Counts 9 and 10.
Dated: January 7, 2026 _s/Douglas L. Micko____________
Douglas L. Micko
United States Magistrate Judge
NOTICE
Filing Objections: This Report and Recommendation is not an order or judgment of the
District Court and is therefore not appealable directly to the Eighth Circuit Court of
Appeals.
Under Local Rule 72.2(b)(1), “a party may file and serve specific written objections to a
magistrate judge’s proposed finding and recommendations within 14 days after being
served a copy” of the Report and Recommendation. A party may respond to those
objections within 14 days after being served a copy of the objections. See Local
Rule 72.2(b)(2). All objections and responses must comply with the word or line limits set
forth in Local Rule 72.2(c).
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