Navratil v. Johnston

Case

Navratil v. Johnston, Civil No. 25-1175 (JRT/LIB)

Judge

John R. Tunheim, United States District Judge. **Decided:** October 31, 2025

Parties and Background Plaintiffs Ryan Navratil, Nicholas Luhmann, Paul Knutson, and Christopher Malz are civilly committed to the Minnesota Sex Offender Program (MSOP), a state facility for sex offender treatment. Defendants are Nancy Johnston, Executive Director of the MSOP, and Shireen Gandhi, Temporary Commissioner of the Minnesota Department of Human Services (DHS), sued in their official capacities only. Between August 2024 and January 2025, each plaintiff received a valid order from a Commitment Appeal Panel (CAP)—a state judicial body—authorizing transfer from a more restrictive MSOP facility to a less-restrictive Community Preparation Services (CPS) facility. Plaintiffs allege that defendants unreasonably delayed executing those transfer orders, violating their procedural due process rights under the Fourteenth Amendment to the U.S. Constitution and Article I, Section 7 of the Minnesota Constitution.

Rule 12(b)(6) Analysis — Three Arguments

Argument 1: No procedural due process claim alleged. Defendants argued that plaintiffs were merely complaining about a delay in execution of their orders, not a lack of process, and therefore had not stated a procedural due process claim. The court rejected this, citing its prior ruling in Rud v. Johnston, 2023 WL 6318615 (D. Minn. Sept. 28, 2023), which held that nearly identical allegations adequately supported a procedural due process claim at the pleading stage. The court found plaintiffs' allegations concerned whether the state 'circumscribed the deprivation with constitutionally adequate procedures,' which is the core of a procedural due process claim.

Argument 2: Waitlist satisfies due process as a 'tenants-in-common / first-in-time' mechanism. Defendants advanced a novel theory: that each CAP order holder holds a property interest as a 'tenant in common' with all other order holders, and that the 'first-in-time' principle (serving the oldest claims first) is the lawful common-law method to reconcile competing interests. The court rejected this theory at the pleading stage. Relying on Rud v. Johnston, 2025 WL 2636455 (D. Minn. Sept. 12, 2025), the court emphasized that the protected interest includes the right to be transferred within a reasonable time—not merely eventually—and that unlike a delayed money judgment (which can be recovered in full), MSOP patients cannot recover lost time. The court declined to hold as a matter of law that a waitlist resembling property reconciliation mechanisms excused any deprivation.

Argument 3: Adequate post-deprivation process exists. Defendants conceded, in light of the Rud summary judgment order, that several process-based arguments were foreclosed. They raised one new argument in their reply brief—that plaintiffs could challenge their waitlist position under Minn. Stat. § 13.04, subd. 4, which allows individuals to contest the accuracy or completeness of government data about themselves, with a 30-day response requirement and an appeal process. The court noted it generally does not consider arguments raised for the first time in a reply brief but addressed it because it was discussed at oral argument. The court held that § 13.04 provides only a mechanism to correct clerical or administrative errors in waitlist placement and does not constitute a meaningful 'opportunity to be heard' sufficient to satisfy the Mathews v. Eldridge balancing test (424 U.S. 319 (1976)), which weighs the individual's interest, the risk of erroneous deprivation, and the government's administrative burden.

Rule 12(b)(7) Analysis — Joinder Defendants argued that all other current holders of valid CAP transfer orders were necessary parties whose absence prevented the court from affording complete relief, because any order favoring plaintiffs (such as moving them up on the waitlist) would harm those other individuals. The court rejected this argument on two independent grounds. First, even if the absent parties were 'necessary' under Rule 19(a), dismissal is only appropriate if they are also 'indispensable'—i.e., joinder is not feasible and the case cannot proceed without them. Defendants did not address feasibility, making dismissal premature. Second, the other CAP order holders are not necessary parties at all because plaintiffs seek additional procedural protections regarding their waitlist status, not a higher position on the waitlist. Providing additional process would not harm the interests of other waitlisted individuals, and complete relief does not require their presence.

Eleventh Amendment — State Constitutional Claim The Eleventh Amendment to the U.S. Constitution generally bars federal courts from ordering state officials to comply with state law. See Pennhurst State School & Hosp. v. Halderman, 465 U.S. 89 (1984). Because plaintiffs sought an injunction against state officials based on violations of the Minnesota Constitution (a state law source), the Eleventh Amendment bars that relief. The court dismissed Count I of the complaint to the extent it rests on the Minnesota Constitution, with prejudice.

Disposition - Plaintiffs' procedural due process claim under the Minnesota Constitution: DISMISSED WITH PREJUDICE. - Plaintiffs' procedural due process claim under the U.S. Constitution (remainder of Count I): MOTION TO DISMISS DENIED; claim proceeds. - Rule 12(b)(7) motion: DENIED.

The case proceeds on the federal constitutional due process claim as a class action.