Minter v. Bartruff, No. 18–2468 (8th Cir. 2019)
Nature of Case: Appellants, individuals who were convicted of sex offenses and confined to the Iowa Department of Corrections, brought a federal § 1983 suit bringing various statutory and constitutional claims against the IDOC’s sex offender treatment program, which they could not participate in due to a limited number of openings and thus were subject to a loss of good-time credits. Specifically, Appellants claimed that the program violated their rights to Equal Protection, Due Process, and necessary medical care under the Eighth Amendment as well as statutory rights to good-time credits.
The district court dismissed the claims for both failure to exhaust administrative remedies under the PLRA, as well as holding that the claims were barred by Heck v. Humphrey. Appellant sought review.
Holding: The 8th Circuit Court of Appeals reversed the judgment of the trial court, finding that the record was not sufficient to conclude that either Appellants had not exhausted their administrative remedies, nor that their claims were barred by Heck — in particular because of the Eighth Amendment claim.