Doranti v. Sims et al

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
Sarprio Doranti,
Plaintiff,
v.
Jeremiah Sims, et al.,
Defendants.
Case No. 25-cv-4356 (NEB/DTS)
REPORT AND RECOMMENDATION
Plaintiff Sarprio Doranti, a client of the Minnesota Sex Offender Treatment
Program (MSOP) in Moose Lake, Minnesota, is currently incarcerated at the Minnesota
Correctional Facility in Stillwater (MCF-Stillwater). He sues MSOP officials largely
claiming that his conditional release was revoked based on behavioral expectation reports
(BERs) that were issued in violation of his constitutional rights. Dkt. No. [1]. Doranti did
not pay the filing fee associated with this matter. Instead, he submitted an application to
proceed in forma pauperis (IFP). Dkt. No. [3]. That application, however, was deficient
because it did not appear to include a certified copy of his prison trust fund statement
signed by an authorized prison official as required by law. See 28 U.S.C. § 1915(a)(2).
Accordingly, this Court previously ordered that he submit a complete IFP application with
the required form signed by the appropriate prison official. See Dkt. No. [5]. The Court
also warned him of potential legal and factual deficiencies with his complaint and
authorized him to submit an amended complaint to correct those deficiencies. Id. Doranti
submitted a complete IFP application, see Dkt. No. [8], which also noted that an amended
complaint was forthcoming. Dkt. No. [8-1]. But no amended complaint has been filed and
the court-imposed deadline for doing so has long passed. This matter is therefore back
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before the Court for preservice review of Doranti’s complaint pursuant to 28 U.S.C.
§ 1915A(a). Upon that review, this Court recommends that Doranti’s complaint be
dismissed without prejudice for failure to state a plausible claim for relief, see 28
U.S.C. § 1915A(b)(1), and that his IFP application be denied as moot.
I. 	IFP Application
Although Doranti is a client of MSOP, he is currently a prisoner at MCF-Stillwater.
His IFP application, therefore, is governed by 28 U.S.C. § 1915(b), which requires that
prisoners seeking IFP status pay an initial partial filing fee upon initiating a civil action,
see Ashley v. Dilworth, 147 F.3d 715, 716 (8th Cir. 1998). The initial partial filing fee owed
by the prisoner-litigant is twenty percent of the greater of the average monthly deposits
to the plaintiff’s facility trust account or the average balance in the plaintiff’s account for
the six-month period immediately preceding the filing of the complaint. See 28 U.S.C. §
1915(b)(1). But “[i]n no event shall a prisoner be prohibited from bringing a civil action or
appealing a civil or criminal judgment for the reason that the prisoner has no assets and
no means by which to pay the initial partial filing fee.” 28 U.S.C. § 1915(b)(4).
Doranti’s IFP application reflects that he has $0.00 on his account and the average
money deposits to his account in the preceding six months was also $0.00. Accordingly,
the Court concludes that Doranti currently has no means and no assets by which to pay
any initial partial filing fee. Doranti may therefore proceed with this action without paying
an initial fee.
But Doranti is cautioned that the entire balance of the $350.00 statutory filing fee
will have to be paid in installments. Officials at the facility where he is confined will be
notified of this requirement and will be authorized to withdraw funds from his facility trust
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account and remit those funds to the Court, consistent with § 1915(b), regardless of the
outcome of this action.
II. 	28 U.S.C. § 1915A(a) Preservice Review
Even though Doranti may pursue this action without paying an initial partial filing
fee, his complaint is nevertheless subject to preservice review pursuant to 28 U.S.C. §
1915A, which provides that the Court must dismiss a complaint, or any portion of it, if it
contains claims that: (1) are frivolous, malicious, or fail to state a claim upon which relief
may be granted; or (2) seek monetary relief from a defendant who is immune from such
relief. 28 U.S.C. § 1915A(b).
A. 	Legal Standard
A claim is frivolous if “it lacks an arguable basis either in law or fact.” Neitzke v.
Williams, 490 U.S. 319, 325 (1989). A claim fails to state a claim upon which relief may
be granted if it does not allege “enough facts to state a claim to relief that is plausible on
its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). Although a “pro se
complaint must be liberally construed,” Topchian v. JPMorgan Chase Bank, N.A., 760
F.3d 843, 849 (8th Cir. 2014), pro se plaintiffs must allege sufficient facts to “nudge[ ] their
claims across the line from conceivable to plausible or their complaint must be dismissed,”
Twombly, 550 U.S. at 569-70.
B. 	Background
Publicly accessible Minnesota state court records show that on October 16, 2023,
Doranti was sentenced to a term of imprisonment of 20 months, followed by a five-year
conditional release term after pleading guilty to one count of fourth degree assault in
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violation of Minn. Stat. § 609.2231.3a(b)(2). See State of Minnesota v. Doranti, Case No.
09-cr-22-2192 (Minn. Dist. Ct.) (Index #46, filed Oct. 16, 2023).
In April 2025, Doranti alleges that Defendant LaGraves wrote a letter to his
conditional release officer that contained false or misleading statements about his
behavior and treatment participation at MSOP, later telling him that she did not believe
that the information contained in the letter was true, but that Defendant Palmer directed
her 	to 	write it. At his 	conditional 	release revocation hearing, Doranti 	claims that
Defendants Palmer and LaGraves did not call any witness or present his treatment
records, which would have reflected his treatment participation. Instead, Doranti alleges
that they relied on “fake” BERs that were issued in violation of his rights to procedural due
process and equal protection under the laws—namely, Doranti claims that the BERs were
often racially motivated and were issued without proper due process protections,
including notice and an opportunity to be heard and to present witnesses. As the Court
understands it, he contends that these “fake” BERs led to the revocation of his conditional
release and his current term of imprisonment. He requests damages and release from all
confinement.
C. 	Analysis
Doranti brings his claims pursuant to 42 U.S.C. §§ 1983 & 1985(3). See Dkt. No.
[1]. To state a claim under 42 U.S.C. § 1983, “a plaintiff must allege a violation of a
constitutional right committed by a person acting under color of state law.” Andrews v.
City of West Branch, Iowa, 454 F.3d 914, 918 (8th Cir. 2006). Section 1985(3), in turn,
“provides a cause of action for damages sustained as a result of conspiracies . . . to
deprive individuals of equal privileges and immunities and equal protection under the law.”
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Kelly v. City of Omaha, Neb., 813 F.3d 1070, 1077 (8th Cir. 2016). There are several
problems with Doranti’s claims. The Court focuses on the three most salient.
1. 	Doranti’s Claims are Heck-barred
First, in Heck v. Humprey, 512 U.S. 477 (1994), the United States Supreme Court
held that “if a judgment favorable to a prisoner in a § 1983 action would necessarily imply
the invalidity of the prisoner’s conviction or the length of the prisoner’s sentence, then a
§ 1983 action for damages does not arise until the conviction or sentence has been
reversed on direct appeal, expunged by executive order, or declared invalid by an
authorized state tribunal, or called into question by the issuance of a federal habeas writ.”
Sheldon v. Hundley, 83 F.3d 231, 233 (8th Cir. 1996) (citing Heck, 512 U.S. at 486-87).
The principle in Heck applies in equal force to prison administrative rulings affecting the
length of a prisoner’s sentence and parole revocation hearings. See id. (listing cases).
Further, Heck is not limited to requests for money damages. Id. Rather, in determining
whether Heck applies, district courts must “disregard the form of relief sought and instead
look to the essence of the plaintiff’s claims.” Id.
In this case, Doranti contends that his current incarceration is unlawful—that he
has been falsely imprisoned—because his conditional release revocation proceedings
were wrongly decided. See Compl. at 37. If Doranti prevailed on his claims, this Court
would be calling into question the legality of those proceedings—this is exactly the result
Heck prohibits. Because Doranti has provided no proof that his underlying conditional
release revocation is invalid, Heck bars this Court from granting the requested relief. This
bar applies to his claims for monetary damages and his request for injunctive relief.
Further, because courts have applied the Heck doctrine not only to § 1983 actions, but
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also to those brought under § 1985, Doranti’s § 1985(3) claim should similarly be
dismissed without prejudice under Heck. 	See Jones v. Carter, Case No. 8:19CV288,
2019 WL 3429821, at *4 (D. Neb. July 30, 2019) (listing cases); see Arrington v. Street,
Case No. 22-cv-2362, 2022 WL 18356337, at *2 (D. Minn. Oct. 25, 2022) (listing cases),
R&R adopted by 2023 WL 204078 (D. Minn. Jan. 17, 2023).
2. 	Doranti has failed to state a plausible claim for relief.
Second, even if Heck were not a bar to relief, Doranti has failed to assert a
plausible constitutional violation under § 1983 or a plausible conspiracy to sustain a claim
under § 1985(3). Doranti contends that MSOP officials have violated his Fourteenth
Amendment rights to (1) procedural due process and (2) equal protection under the laws.
a. 	Doranti has failed to assert a plausible Due Process claim
To establish a procedural due process violation, Doranti must show that (1) he was
deprived of a protected liberty or property interest, and, if so, (2) that the defendants
denied him the process he was due. See Senty-Haugen v. Goodno, 462 F.3d 876, 886
(8th Cir. 2006). Doranti’s due process claim does not pass the first element. “Protected
liberty interests may arise from two sources—the Due Process Clause itself and the laws
of the States.” Ky. Dep’t of Corr. v. Thompson, 490 U.S. 454, 460 (1989). “The touchstone
of the inquiry into the existence of a protected, state-created liberty interest in avoiding
restrictive conditions of confinement is not the language of regulations regarding those
conditions but the nature of those conditions themselves in relation to the ordinary
incidents of prison life.” Wilkinson v. Austin, 545 U.S. 209, 223 (2005) (citing Sandin v.
Conner, 515 U.S. 472, 484 (1995)). This inquiry requires courts to consider whether the
restriction “present[s] a dramatic departure from the basic conditions of the [inmate’s
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detention].” Id. “Disciplinary measures that do not substantially worsen the conditions of
confinement of a lawfully confined person are not actionable under the due process
clause . . . regardless of whether the confinement is criminal or civil.” Miles v. Korby, Case
No. 17-cv-0263, 2017 WL 1169639 (D. Minn. Mar. 3, 2017) (quoting Miller v. Dobier, 634
F.3d 412, 414-15 (7th Cir. 2011)) (citations omitted), R&R adopted by 2017 WL 1169536
(D. Minn. Mar. 28, 2017).
Here, Doranti says that while most of the “fake” BERs were dismissed, those that
were sustained resulted in him losing canteen privileges for three to seven days. Compl.
at ¶31. The loss of canteen privileges for three to seven days simply does not amount to
a “deprivation[] which work[s] such major disruptions in a prisoner’s environment and life
that they present dramatic departures from the basic conditions and ordinary incidents of
prison sentences.” Christianson v. Clarke, 932 F.Supp. 1178, 1182 (D. Neb. 1996)
(concluding that the temporary denial of privileges such as “free access to the law library,
circulating library, yard, central dining, canteen and basic other freedoms shared by the
inmate population as a whole” do not present “the type of atypical, significant deprivations
in which a state might conceivably create a liberty interest”); see also Miles, 2017 WL
1169639 at *3 (concluding that the denial of MSOP clients’ access to a particular gym
and multipurpose room did not implicate a protected liberty interest thereby triggering due
process considerations). Since the temporary loss of canteen privileges does not
implicate a protected liberty interest and Doranti points to no other consequence or loss
stemming from the BERs, Doranti has failed to assert an actionable procedural due
process claim under § 1983.1
1 To the extent, moreover, that Doranti claims that MSOP officials violated his due process
rights by failing to comply with their own policies, see Compl. at ¶ 32, it is well-established
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b. Doranti has failed to assert a plausible Equal Protection claim.
This 	leaves 	Doranti’s 	equal 	protection 	claim. 	“The 	Equal 	Protection 	Cause
generally requires the government to treat similarly situated people alike.” Klinger v. Dep’t
of Corr., 31 F.3d 727, 731 (8th Cir. 1994) (citation omitted). “Dissimilar treatment of
dissimilarly situated persons does not violate equal protection.” Id. “Thus, the first step in
an equal protection case is determining whether the plaintiff has demonstrated that [he]
was treated differently than others who were similarly situated to [him].” Id. “Absent a
threshold showing that [he] is similarly situated to those who allegedly receive favorable
treatment, the plaintiff does not have a viable equal protection claim.” Id.
Doranti endeavors to meet this threshold by identifying several instances where
white MSOP clients did not receive BERs for conduct he considers substantially more
egregious than the conduct that purportedly triggered his BERs. See Dkt. No. [1]. The
problem with Doranti’s approach is its level of generality. He asserts no facts suggesting
that these white MSOP clients were similarly situated as to him—namely, subject to
conditional release for an assault conviction. Accordingly, Doranti has failed to assert a
plausible Equal Protection claim, as well.
c. 	Doranti has failed to assert a plausible 42 U.S.C. § 1985(3) claim
Finally, “[i]n order to state a claim for conspiracy under § 1985, a plaintiff ‘must
allege 	with 	particularity 	and 	specifically 	demonstrate 	with 	material 	facts 	that 	the
defendants reached an agreement.’” Kelly, 813 F.3d at 1077-78 (quoting City of Omaha
that the failure to comply with policy, by itself, does not amount to a liberty interest
triggering due process considerations. See Olim v. Wakinekona, 461 U.S. 238, 250
(1983) (“The State may choose to require procedures for reasons other than protection
against deprivation of substantive rights, of course, but in making that choice the State
does not create an independent substantive right.”).
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Emps. Betterment Ass’n v. City of Omaha, 883 F.2d 650, 652 (8th Cir. 1989)). “This
standard requires that ‘allegations of a conspiracy [be] pleaded with sufficient specificity
and factual support to suggest a meeting of the minds directed toward an unconstitutional
action.” Id. at 1078 (quoting Nelson v. City of McGehee, 876 F.2d 56, 59 (8th Cir. 1989)).
Here, as described above, Doranti has failed to assert a plausible equal protection
violation. That said, he has also failed to assert any specific facts establishing that the
defendants reached a “meeting of the minds” to violate his constitutional rights. While
Doranti claims that Defendant LaGraves told him that her letter to his conditional release
officer was written at the direction of Defendant Palmer, this allegation falls well short of
establishing that Defendant LaGraves conspired with Defendant Palmer (or anyone else)
to violate his constitutional rights. Doranti’s § 1985(3) claim should also therefore fail as
a matter of law.
In conclusion, therefore, this Court recommends that Doranti’s claims be dismissed
for failure to state a plausible claim for relief. See 28 U.S.C. § 1915A(b)(1).
RECOMMENDATION
Based on the foregoing, and on all of the files, records, and proceedings herein,
THE COURT RECOMMENDS THAT:
1. 	Plaintiff Sarprio Doranti’s Complaint, Dkt. No. [1], be DISMISSED WITHOUT
PREJUDICE for failure to state a plausible claim for relief, see 28 U.S.C.
§ 1915A(b)(1);
2. 	Plaintiff’s application to proceed in forma pauperis (IFP), Dkt. No. [3] & [8], be
DENIED as MOOT; and
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3. 	Plaintiff should be required to pay the unpaid balance of this action’s statutory filing
fee ($350.00) in the manner prescribed by 28 U.S.C. § 1915(b)(2), and Clerk of
Court should be required to provide notice of this requirement to the authorities at
the institution where Doranti is confined.
Dated: January 29, 2026 	__s/ David T. Schultz__________
DAVID T. SCHULTZ
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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