Evangelista v. Federal Bureau of Prisons and the Warden of F.P.C. Duluth
- Katherine Menendez
- 0:25-cv-00777
- U.S. District Court · District of Minnesota
- 3
In Evangelista v. Federal Bureau of Prisons and the Warden of F.P.C. Duluth, Judge Katherine Menendez dismissed without prejudice the lawsuit filed by federal prisoner Wayne Evangelista, overruling his objections to a magistrate judge's recommendation and finding that the complaint lacked jurisdiction and failed to state a valid legal claim.
Federal prisoners who file civil rights or statutory claims against the Bureau of Prisons or prison officials, particularly those whose complaints are screened before service under the federal prisoner litigation screening statute.
What happened
In Evangelista v. Federal Bureau of Prisons and the Warden of F.P.C. Duluth, Wayne Evangelista, a federal prisoner who was held at the Federal Prison Camp in Duluth, Minnesota when he filed suit, brought six constitutional and statutory claims against the Federal Bureau of Prisons and the warden of that facility, based on his alleged treatment while incarcerated there. He also asked the court for permission to proceed without paying filing fees (known as an 'in forma pauperis' application, meaning he claimed he could not afford court costs).
U.S. Magistrate Judge John F. Docherty reviewed the complaint before it was formally served on the defendants, as required by federal law when a prisoner seeks to proceed without paying fees, and issued a detailed report recommending that the case be dismissed because the court lacked jurisdiction and because the complaint did not state legally valid claims. Evangelista filed objections, arguing generally that he had documentation to support his claims and contending — incorrectly, as the court found — that a recent Supreme Court decision called Loper Bright Enterprises v. Raimondo opened the door to holding the warden personally liable. The court explained that Loper Bright dealt only with how much courts defer to federal agencies' interpretations of the law, and has nothing to do with whether government officials can be held personally liable.
Judge Katherine Menendez overruled Evangelista's objections, adopted the magistrate judge's report and recommendation in full, and dismissed Evangelista's complaint without prejudice — meaning he is not permanently barred from refiling, though no assurance of success on refiling is implied. His request to proceed without paying filing fees was denied as moot, since the case was dismissed.
The detailed version
This case arises from a lawsuit filed on March 3, 2025, by Wayne Evangelista, then an inmate at the Federal Prison Camp in Duluth, Minnesota (FPC-Duluth), against the Federal Bureau of Prisons (BOP) and the Warden of FPC-Duluth. The complaint alleged six constitutional and statutory claims stemming from Evangelista's treatment at FPC-Duluth. Evangelista simultaneously filed a motion for leave to proceed in forma pauperis (IFP) — a request to waive filing fees based on inability to pay.
Pursuant to 28 U.S.C. § 1915(e)(2), which requires courts to screen complaints filed by prisoners seeking IFP status before service on defendants, U.S. Magistrate Judge John F. Docherty reviewed the complaint and issued a Report and Recommendation (R&R) on June 12, 2025. The R&R recommended dismissal without prejudice on two independent grounds: (1) lack of subject-matter jurisdiction, and (2) failure to state a claim upon which relief can be granted. Judge Docherty also recommended that the IFP application be denied as moot given the recommended dismissal.
Evangelista filed timely objections on June 23, 2025. Under 28 U.S.C. § 636(b)(1) and District of Minnesota Local Rule 72.2(b), the district court reviews de novo (anew, without deference to the magistrate) any portion of the R&R to which specific objections are made, and reviews the remainder for clear error. The court found that Evangelista's objections were largely general — asserting that he had documentation to support his claims — without engaging specifically with the magistrate's legal analysis. Because the objections lacked specificity, the court applied the clear-error standard to most of the R&R and found none.
One objection received de novo review: Evangelista argued that the Supreme Court's decision in Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), which overturned Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), opened the Warden to personal liability. Judge Menendez rejected this argument, explaining that both Loper Bright and Chevron concerned the degree of deference courts owe to federal agencies' interpretations of statutes they administer — not the circumstances under which government officials can be held personally liable. The court found the R&R's statement of governing law on federal agency and officer liability to be accurate and correctly applied.
The court also briefly addressed Evangelista's unsubstantiated allegation of district-wide bias on the part of Judge Docherty, finding it unexplained and unsubstantiated and therefore not meriting further analysis.
The court noted in a footnote that Evangelista appears to have since been transferred to the Federal Correctional Institution in Ashland, Kentucky.
The court's order: (1) overruled Evangelista's objections; (2) accepted and adopted the R&R in full; (3) dismissed the complaint without prejudice (meaning Evangelista is not permanently barred from refiling, subject to applicable legal requirements); and (4) denied the IFP motion as moot. Judgment was entered accordingly. The opinion was signed by United States District Judge Katherine Menendez on October 16, 2025.
Reviewer note from the AI+
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.