Crump v. Minnesota Department of Corrections

Crump v. Minnesota Department of Corrections, Tracy Beltz, and Paul Schnell Case No. 26-CV-0693 (PJS/JFD) | U.S. District Court, District of Minnesota | March 19, 2026 Magistrate Judge John F. Docherty

Procedural Posture Plaintiff Willie James Crump, a prisoner, filed a civil complaint (Dkt. No. 1) against the Minnesota Department of Corrections, Tracy Beltz, and Paul Schnell, and simultaneously applied for in forma pauperis (IFP) status — permission to proceed without prepaying the full filing fee (Dkt. No. 2).

IFP Fee Calculation Under 28 U.S.C. § 1915(b), prisoners seeking IFP status in civil actions must pay an initial partial filing fee equal to 20 percent of the greater of (1) average monthly deposits to their facility trust account during the preceding six months, or (2) the average balance in that account during the same period. Mr. Crump's prison official certificate (Dkt. No. 4) showed average monthly deposits of $110.99, and his trust-account statement (Dkt. No. 4-1) showed an average balance of $73.21 for part of the period. Because the deposits figure exceeded the balance figure, the court applied 20 percent to $110.99, yielding an initial partial fee of $22.19. The court noted that Mr. Crump may have been transferred between facilities during the relevant period and declined to require additional account records from prior facilities.

Order The court ordered Mr. Crump to pay the $22.19 initial partial filing fee within 21 days. If he fails to do so, the court will recommend dismissal without prejudice under Federal Rule of Civil Procedure 41(b) for failure to prosecute. The case will not proceed until the fee is paid.

Warnings Issued The court issued two significant warnings: 1. Remaining fee obligation: If Mr. Crump pays the initial fee, he will still owe the remaining $327.91 of the $350.00 statutory filing fee, to be collected in installments from his trust account by prison officials under § 1915(b), regardless of the case outcome. 2. Frivolity review and 'strikes': Upon payment, the court will screen the complaint under § 1915 to determine whether it states a viable claim. If the complaint is found frivolous, malicious, or legally insufficient, Mr. Crump will accrue a 'strike' under 28 U.S.C. § 1915(g). Three or more strikes substantially restrict a prisoner's ability to proceed IFP in future federal civil actions.

Substantive Concerns Flagged (Footnote) In a detailed footnote, Magistrate Judge Docherty identified several apparent legal deficiencies in the complaint: - Eleventh Amendment sovereign immunity: The Minnesota Department of Corrections, as a state agency, is 'completely shielded' from this lawsuit under the Eleventh Amendment, which generally bars suits in federal court against states and their agencies. - Personal involvement: Civil-rights claims under 42 U.S.C. § 1983 require that each individual defendant was personally involved in the alleged constitutional violation. The complaint allegedly fails to plead such involvement for Tracy Beltz and Paul Schnell. - Prison Rape Elimination Act (PREA): Mr. Crump's claims relying on PREA appear barred because that statute does not give individual prisoners a private right of action (i.e., the right to sue in court to enforce it). - Prison wage deductions: Challenges to legally authorized prison wage deductions are likely barred as a matter of law. The court advised Mr. Crump to carefully consider whether to commit $350.00 to pursue the litigation in light of these concerns.

Ruling The court ordered Mr. Crump to pay an initial partial filing fee of $22.19 within 21 days of March 19, 2026. Failure to pay will result in a recommendation to dismiss without prejudice for failure to prosecute.