Summary
This Eighth Circuit opinion affirms the district court's grant of summary judgment dismissing civilly committed MSOP clients' religious liberty claims against the Minnesota Department of Human Services. The appellate court held that the plaintiffs' claims regarding pandemic-era restrictions on spiritual groups were moot, as those restrictions had been lifted. Furthermore, the court found that challenges to the facility's current policies were not properly pled in the operative complaint and denied the plaintiffs' motion to supplement the record. Consequently, the appeal was dismissed for lack of jurisdiction due to mootness.
Topics
Practice areas
Questions Presented
- Whether the plaintiffs' claims are moot because the pandemic‑era restrictions have ceased
- Whether the district court erred in granting summary judgment based on pleading deficiencies
- Whether the appellate court should enlarge the record by allowing supplemental discovery documents
Holdings
- The district court's summary‑judgment dismissal is affirmed because the pandemic‑era policies are no longer in effect and the complaint does not properly allege a claim based on the current policies.
- The district court correctly granted summary judgment because the plaintiffs failed to plead the current‑policy claims and therefore no genuine issue of material fact existed.
- The motion to supplement the record is denied because the plaintiffs failed to show diligence and the supplemental documents would not affect the outcome.
Key quotations
““Summary judgment is proper only if there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law.”” (at 717)
““Thus, while we recognize that the pleading requirements under the Federal Rules are relatively permissive, they do not entitle parties to manufacture claims, which were not pled, late into the litigation for the purpose of avoiding summary judgment.”” (at 717)
Factual background
The Minnesota Sex Offender Program allowed incarcerated clients to join spiritual groups, requiring at least six participants and a volunteer spiritual resource. During the COVID‑19 pandemic the program halted in‑person gatherings and later imposed mask and vaccination requirements. After the public health emergency ended, the program reinstated pre‑pandemic policies but retained the six‑person minimum and prohibited video or livestream participation.
Procedural history
Plaintiffs filed suit alleging that MSOP’s pandemic-era restrictions on spiritual groups violated the Constitution and RLUIPA. The district court granted summary judgment, finding the claims moot because the pandemic restrictions had ended and the complaint did not plead current‑policy claims. Plaintiffs appealed and moved to supplement the record with discovery responses.