Minter v. Bartruff, No. 18-2468 (8th Cir. 2019)
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Iowa inmates filed a 42 U.S.C. 1983 action against the IDOC and IDOC officials, alleging that IDOC's administration of its Sex Offender Treatment Program violates their constitutional rights to equal protection, due process, and necessary medical care.
The Eighth Circuit held that the district court erred in concluding that the federal claims must be dismissed without prejudice under 42 U.S.C. 1997e(a), because plaintiffs failed to exhaust their available post-conviction remedies under Belk v. State, 905 N.W.2d 185, 191 (Iowa 2017). In this case, defendants cite no case holding that post-conviction judicial remedies were "administrative remedies" that must be exhausted under section 1997e(a), and the court has not found an opinion that even addresses the question. The panel also held that plaintiffs' claim that defendants' unconstitutional conduct deprived plaintiffs of their statutory right to accrue earned-time credit and of receiving a reduction of sentence was barred by Heck v. Humphrey, 512 U.S. 477 (1994). Accordingly, the panel reversed and remanded for further proceedings.
Court Description: Loken, Author, with Kelly and Erickson, Circuit Judges] Prisoner case - Prisoner civil rights. In action alleging the Iowa Department of Corrections administration of its Sex Offender Treatment Program violated plaintiffs' constitutional rights to due process, equal protection and necessary medical care, the district court erred in concluding that the federal claims must be dismissed without prejudice under 42 U.S.C. Sec. 1997e(a) because plaintiffs had not exhausted their available post-conviction remedies under Belk v. State, 905 N.W.2d 185, 191 (Iowa 2017); this issue must be remanded as it is not clear on this record what administrative remedies might be available to the plaintiffs; plaintiffs' complaint that the defendants' unconstitutional conduct deprived them of their statutory rights to accrue good-time credit was Heck-barred; because the district court dismissed the entire matter without prejudice, it had not considered plaintiffs' necessary medical care claims and claims for prospective injunctive relief to remedy allegedly unconstitutional procedures in administering the program, and those claims should be considered on remand.
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