Traylor v. Stone
- Laura Provinzino
- 0:24-cv-04619
- U.S. District Court · District of Minnesota
- 8
In Traylor v. Stone, Judge Provinzino dismissed without prejudice the remaining civil rights claim brought by Minnesota prisoner Rayco Traylor after he failed to identify the unnamed prison staff defendants by the court's deadline, overruling his objections to the magistrate judge's recommendation.
Incarcerated individuals who file civil rights lawsuits in federal court using unnamed 'John Doe' or 'Jane Doe' defendants, particularly those who may face difficulty identifying specific prison staff responsible for alleged violations. This opinion reinforces that such plaintiffs must identify and name defendants within court-ordered deadlines and must plead specific enough facts to permit identification through discovery, or risk dismissal.
What happened
In Traylor v. Stone (Case No. 24-cv-4619), Minnesota prisoner Rayco Traylor filed a lawsuit under 42 U.S.C. § 1983 — a federal law allowing people to sue government officials for violating their constitutional rights — alleging that unnamed staff at Minnesota Correctional Facility, Stillwater denied him his prescribed medications for a week in December 2024, among other claims. Earlier in the case, a magistrate judge recommended dismissing most of Traylor's claims but allowed the medication-denial claim to continue on the condition that Traylor identify the unnamed 'John and Jane Doe' defendants within 90 days. Traylor never filed the required amended complaint naming those individuals.
After Traylor missed the May 27, 2025 deadline, the magistrate judge recommended dismissing the remaining claim as well. Traylor objected, arguing that the magistrate judge was biased against him, that prison officials had refused to give him records he needed to identify the defendants, and that he deserved a new hearing on the previously dismissed claims. The court found none of these arguments persuasive: prior rulings against a party are not evidence of judicial bias, Traylor never alerted the court to his discovery difficulties before the deadline despite filing another letter at that time, and his objections to the earlier dismissals were filed too late.
Judge Provinzino adopted the magistrate judge's recommendation in full and dismissed Traylor's complaint without prejudice — meaning Traylor is not permanently barred from refiling, though the court noted that his allegations were too vague to identify the specific staff members involved even through additional investigation. The court also denied Traylor's request for discovery, explaining that a plaintiff must first state a viable claim before being entitled to gather evidence, and that Traylor's complaint lacked enough specifics to support targeted discovery to identify the unnamed defendants.
The detailed version
- Traylor v. Stone, No. 24-cv-4619 (LMP/JFD), United States District Court, District of Minnesota
- Laura M. Provinzino, United States District Judge
- September 30, 2025
Background
Plaintiff Rayco Traylor, an inmate at Minnesota Correctional Facility, Stillwater (MCF-Stillwater), filed a pro se (self-represented) Section 1983 action on December 23, 2024, alleging constitutional violations including neglect, harassment, retaliation, deprivation of liberty, pain and suffering, conspiracy, violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA, 42 U.S.C. § 2000cc), and unconstitutional strip searches. Specifically, Traylor claimed his religious liberties were violated by repeated strip searches and that unnamed MCF-Stillwater staff denied him prescribed medications.
Procedural History
On February 24, 2025, United States Magistrate Judge John F. Docherty issued a Report and Recommendation (R&R) recommending dismissal of most of Traylor's claims, preserving only his Section 1983 claim related to medication deprivation from December 11–17, 2024. The magistrate judge noted that no defendant had been named and ordered Traylor to file an amended complaint within 90 days identifying those individuals. Traylor did not object to that R&R, and the district court adopted it in full on April 8, 2025, giving Traylor until May 27, 2025 to file an amended complaint.
Traylor did not file an amended complaint by the deadline. The only filing before the deadline was a letter asking the court to dismiss a named defendant, Staci Stone, with no mention of any difficulty identifying other defendants. On August 14, 2025 — nearly three months after the deadline — Traylor filed another letter stating he had been denied discovery from prison officials, requesting a 'rehearing' on previously dismissed claims, raising new allegations about prison conditions, and asking for broad discovery including disciplinary reports, videos, staff reports, medical records, and other files.
On August 18, 2025, Magistrate Judge Docherty issued a second R&R recommending dismissal of the remaining medication-deprivation claim due to Traylor's failure to comply with the court's order. Traylor timely objected on August 26, 2025, raising three arguments: (1) bias by Magistrate Judge Docherty based on prior adverse rulings; (2) inability to identify defendants due to denied discovery requests; and (3) a renewed request for rehearing on previously dismissed claims.
Court's Analysis
Timeliness of Objections: The court found that Traylor's objections to the February R&R were untimely — the deadline for those objections was March 10, 2025 — and overruled them accordingly under D. Minn. L.R. 72.2(a)(1).
Bias Claim: Applying 28 U.S.C. § 455(a), the court reiterated the presumption of judicial impartiality and placed the burden on Traylor to show otherwise. Citing Liteky v. United States, 510 U.S. 540, 555 (1994), the court held that judicial rulings alone almost never constitute valid grounds for a bias finding. Traylor's claim amounted to unsupported speculation, and the court found no evidence of actual bias by Magistrate Judge Docherty.
Failure to Amend/Discovery Request: The court rejected Traylor's argument that he should be excused from the deadline because prison officials denied his discovery requests. The court noted that Traylor claims he was denied discovery in February or March 2025 but never raised this issue with the court before the May 27, 2025 deadline — despite filing a letter with the court on May 16, 2025. His failure to comply with the court's order warranted dismissal under Federal Rule of Civil Procedure 41(b), citing Henderson v. Renaissance Grand Hotel, 267 F. App'x 496, 497 (8th Cir. 2008).
Additionally, the court held that no plaintiff — including a pro se litigant — is entitled to discovery before filing a plausible claim for relief. Citing Triemert v. Washington Cnty., 2013 WL 6729260 (D. Minn. 2013), the court explained that discovery rights attach only after a viable claim is pled.
The court also analyzed the law on unnamed 'Doe' defendants. Generally, plaintiffs may not sue fictitious parties in federal court, but there are two narrow exceptions: (1) named Doe defendants must be identified and served within 90 days; and (2) an action may proceed against an unnamed party if the complaint is specific enough to permit identification through reasonable discovery. Citing Perez v. Does 1-10, 931 F.3d 641, 646 (8th Cir. 2019), and Kaplan v. Harrington, 2023 WL 1797872 (D. Minn. 2023), the court found neither exception applied here. Traylor's complaint failed to identify whether the individuals who withheld his medication were physicians, nurses, correctional staff, or some combination, making targeted discovery impossible without a sweeping and impermissible fishing expedition.
Disposition
Judge Provinzino adopted the August R&R in full, overruled Traylor's objections, denied his request for discovery, and dismissed Traylor's complaint without prejudice. Dismissal without prejudice means Traylor is not permanently barred from refiling, though any future filing would need to overcome the same identification and pleading deficiencies identified in this opinion.
Reviewer note from the AI+
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.