Kevin Karsjens v. Jodi Harpstead, No. 22-1459 (8th Cir. 2023)
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This case was brought by a class of sex offenders (Appellants) civilly committed to the Minnesota Sex Offender Program (MSOP) pursuant to the Minnesota Civil Commitment and Treatment Act: Sexually Dangerous Persons and Sexual Psychopathic Personalities, codified at Minnesota Statute Section 253D (MCTA). Appellants filed this action against various MSOP managers and officials, as well as the Commissioner of the Minnesota Department of Human Services (collectively, Appellees). On remand after a second appeal to this Court, the district court granted judgment in favor of Appellees on all of Appellants’ claims. Appellants appeal, challenging the district court’s judgment.
The Eighth Circuit affirmed. The court explained that Appellants contend that the district court erred by declining to address their treatment-related claims, alleging that the district court found them to be duplicative of previously decided counts. The court wrote that in making this finding, the district court did not dismiss or otherwise ignore any of the counts before it, which were all conditions-of-confinement and inadequate medical care claims. While Appellants attempted to “reanimate” these claims in a Fourth Amended Complaint, the district court denied the amendment, and Appellants do not challenge that decision on appeal. Accordingly, the court perceived no error in the district court’s treatment of Appellants’ treatment-related claims. Appellants additionally attacked the district court’s conclusion that the MSOP’s Behavioral Expectation Report policy is constitutional. But Appellants focused only on the impact of the policy on their treatment and fail to address the other legitimate government objectives it addresses—such as preserving institutional order at the MSOP.
Court Description: [Shepherd, Author, with Erickson and Grasz, Circuit Judges] Civil case - Civil Rights. For the court's prior opinions reversing the district court's judgment in favor of the plaintiff class of sex offenders civilly committed to the Minnesota Sex Offender Program pursuant to the Minnesota Civil Commitment and Treatment Act on their claims that the MCTA is unconstitutional on procedural due process grounds and reversing the district court's subsequent application of the "shocks the conscience" standard to grant judgment in favor of defendants on the offenders' claims that defendants are violating their rights to be free from punishment, to less restrictive alternative confinement, and to be free from inhumane treatment, see Karsjens v. Piper, 845 F.3d 394 (8th Cir. 2017) and Karsjens v. Lourey, 988 F.3d 1047 (8th Cir. 2021), respectively. On remand for a second time, the district court granted judgment in favor of defendants, reasoning that there was no evidence the continuum of MSOP facilities is punitive, that plaintiffs have not raised any treatment-related claims, and that the conditions-of-confinement claims fail because the challenged conditions are not punitive under Bell v. Wolfish, 441 U.S. 520 (1979). Held: plaintiffs waived any reliance on Youngberg v. Romero, 457 U.S. 307 (1982) by not raising the issue before the district court or in the earlier appeals; plaintiffs' remaining challenges to the conditions of their confinement fail under Bell; and the inadequate-medical-care claims fail in the absence of any evidence plaintiffs have been injured by defendants' allegedly unconstitutional actions.
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