Karsjens v. Harpstead (D. Minn. 2022)

Karsjens v. Harpstead, No. 11-3659 (D. Minn. 2022)

Nature of Case: Plaintiffs had brought a civil rights challenge to the constitutionality of their continued confinement in Minnesota’s civil commitment facility (“MSOP”). They had previously won at the district court level, which was reversed on appeal in Karsjens I. On remand, the district court evaluated the remaining claims and dismissed them in line with the 8th Circuit’s opinion in Karsjens I. Plaintiffs appealed.

8th Circuit Court of Appeals reversed in part, finding that the lower court had used the incorrect standard in evaluating claims related to the conditions of their confinement. Specifically, the 8th Circuit determined that the district court should have considered the claim of inadequate medical care under the “deliberate indifference standard” outlined in Senty-Haugen v. Goodno, 462 F.3d 876, 889-90 (8th Cir. 2006), and the remaining conditions of confinement claims under the standard for punitive conditions outlined in Bell v. Wolfish, 441 U.S. 520, 535 (1979). On those claims, the Court reversed, but otherwise affirmed the judgment of the trial court.

Holding: On remand from the 8th Circuit, the district court, applying the standards identified by the 8th Circuit found that Plaintiffs’ challenged conditions of confinement serve legitimate governmental objectives that are not excessive, arbitrary, or purposeless, and are not punitive under Bell. The Court also found insufficient evidence to conclude that Defendants were deliberately indifferent to any specific illness or injury, much less at the policy level or on a widespread basis, or that any alleged indifference caused any actual injury or harm.  In so holding, the Court stated “While the Court . . . previously found aspects of the MSOP to be unconstitutional, the Court is bound by the law as it currently exists and cannot conclude that Plaintiffs have proven their remaining claims under the governing legal standards.”