Corey Lamont Jackson v. Wendy Monfils, Sarah Cooper, and Warden Brian Cahak

Summary

The United States District Court for the Eastern District of Wisconsin granted Corey Lamont Jackson leave to proceed without prepaying the filing fee but found that his complaint failed to state a claim. The court rejected his Fifth Amendment takings and Fourteenth Amendment due process theories as currently pleaded, while granting him leave to amend by June 2, 2026. The order also denied as moot his motions to use release-account funds and directed collection of the remaining filing fee balance.

Holdings

1. The complaint did not state a categorical takings claim because Jackson did not allege that the defendants took his property for public use.
2. Although the alleged restriction on use of the tablet property could potentially constitute a regulatory takings claim at the pleading stage, Jackson could not proceed on the claim as pleaded because he sought only monetary damages and did not seek prospective relief against an ongoing violation.
3. The complaint failed to state a viable due-process claim because Wisconsin provided adequate post-deprivation statutory and tort remedies for the alleged loss of personal property.
4. Jackson was granted leave to file an amended complaint supplying sufficient facts identifying who violated his rights, what each defendant did, and where and when the alleged violations occurred.

Questions Presented

1. Whether Jackson's allegations stated a Fifth Amendment categorical or regulatory takings claim under 42 U.S.C. § 1983.
2. Whether Jackson's claim for monetary compensation for the alleged deprivation of property was barred by sovereign immunity.
3. Whether the alleged deprivation of property stated a Fourteenth Amendment due-process claim when Wisconsin provided post-deprivation statutory remedies.
4. Whether Jackson should be granted leave to amend after the complaint failed to state a claim.

Disposition

other