Horswell v. All 50 States and the District of Columbia
- Paul Magnuson
- 0:25-cv-04563
- U.S. District Court · District of Minnesota
- 3
In Phillip Horswell v. All 50 States and the District of Columbia, Judge Magnuson dismissed without prejudice the lawsuit filed by civil detainee Phillip Horswell challenging the legality of civil detention, finding that he cannot attack his ongoing civil detention through a non-habeas federal lawsuit.
Civil detainees, particularly those held under state civil-detention statutes, who attempt to challenge the legality of their confinement through standard civil federal lawsuits rather than through habeas proceedings in state courts first.
What happened
In Phillip Horswell v. All 50 States and the District of Columbia, Phillip Horswell, a person civilly detained by the State of Minnesota, sued all fifty states and the District of Columbia, arguing that civil detention is unlawful and that civil-detention laws across the country violate the law. He asked the court to waive the filing fee because he could not afford it (a request called proceeding without prepayment of fees, or 'IFP').
The court found that while Horswell financially qualifies for the fee waiver, federal law requires dismissal of a case — even one where the fee is waived — when the complaint fails to state a valid legal claim. The court explained that Horswell has been told in prior federal cases that he cannot challenge his civil detention through a regular civil lawsuit; the proper vehicle would be a petition for a writ of habeas corpus (a legal request to challenge the legality of one's confinement), and even then, he would first need to exhaust his options in state courts. The court also noted that because Horswell is not a licensed attorney, he cannot bring claims on behalf of other civil detainees across the country — he can only represent himself.
Judge Magnuson dismissed the case without prejudice, meaning Horswell is not permanently barred from filing again, and denied his request to proceed without paying the filing fee. The dismissal is based on the legal rule, established in the U.S. Supreme Court case Heck v. Humphrey, that a person cannot use a standard civil lawsuit to challenge a confinement that is backed by a facially valid court judgment.
The detailed version
Case: Phillip Horswell v. All 50 States and the District of Columbia, Civil No. 25-4563 (PAM/DLM), U.S. District Court for the District of Minnesota. Decided December 10, 2025, by United States District Court Judge Paul A. Magnuson.
Background
Plaintiff Phillip Horswell is a civil detainee of the State of Minnesota. He filed a pro se (self-represented) complaint naming all fifty states and the District of Columbia as defendants, alleging that civil detention is unlawful and that civil-detention statutes nationwide violate the law. Horswell did not pay the filing fee and instead applied for in forma pauperis (IFP) status, which allows qualifying individuals to proceed without prepaying court fees.
IFP Review
The court confirmed that Horswell qualifies financially for IFP status. However, under 28 U.S.C. § 1915(e)(2)(B)(ii), the court is required to dismiss an IFP action that fails to state a claim on which relief may be granted. The court applied the standard pleading framework from Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. 662 (2009), requiring that a complaint state a plausible claim for relief, not merely speculative allegations. Pro se complaints are read liberally but must still allege sufficient facts.
Analysis
The court found Horswell's complaint to be a direct attack on the legality of his ongoing civil detention. The court noted this is not Horswell's first attempt to challenge his detention in federal court: prior cases (Civ. No. 25-1004 and Civ. No. 24-0949) had already informed him that (1) he cannot challenge civil detention through a standard civil (non-habeas) federal lawsuit under the rule of Heck v. Humphrey, 512 U.S. 477 (1994), as interpreted and applied in Thomas v. Eschen, 928 F.3d 709 (8th Cir. 2019), and (2) he cannot pursue habeas relief on claims not yet exhausted in state courts. The court applied the Heck doctrine, which bars civil claims that would necessarily imply the invalidity of a facially valid judgment of confinement. The court also noted that Horswell, as a non-attorney, lacks the legal authority under 28 U.S.C. § 1654 to litigate claims on behalf of other civil detainees nationwide.
Ruling
The court dismissed the case without prejudice (meaning Horswell is not permanently barred from refiling if circumstances change) pursuant to 28 U.S.C. § 1915(e)(2)(B), citing Gautreaux v. Sanders, 395 F. App'x 311 (8th Cir. 2010), for the proposition that Heck-based dismissals should be without prejudice. The IFP application was denied.
Reviewer note from the AI+
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.