Dalen v. Harpstead

U.S. District Court, District of Minnesota

Dalen v. Harpstead

Trial Court Opinion

             UNITED STATES DISTRICT COURT                            
                DISTRICT OF MINNESOTA                                


Kyle Jerome Dalen, individually and on    File No. 23-cv-1877 (ECT/ECW)   
behalf of all others similarly situated,                                  

     Plaintiff,                                                      

v.                                       OPINION AND ORDER                

Jodi Harpstead, Commissioner of the                                       
Minnesota Department of Human Services,                                   
in her individual and official capacities,                                

     Defendant.                                                      


Daniel E. Gustafson, David A. Goodwin, Anthony J. Stauber, and Joseph E. Nelson, 
Gustafson Gluek PLLC, Minneapolis, MN; Kevin J. Wetherille and James P. Conway, 
Jaspers Moriarty & Wetherille, P.A., Shakopee, MN; Jason D. Gustafson, Throndset 
Michenfelder Law Office, LLC, St. Michael, MN, and Hannah L. Scheidecker, Fremstad 
Law, Fargo, ND, for Plaintiff Kyle Jerome Dalen.                          

Aaron Winter and Sparrowleaf Dilts McGregor, Office of the Minnesota Attorney General, 
St. Paul, MN, for Defendant Jodi Harpstead.                               


Plaintiff Kyle Jerome Dalen was under a civil commitment order while in the 
custody of a Minnesota county jail facing criminal charges.  Mr. Dalen claims that a 
Minnesota  statute,  Minn.  Stat.  §  253B.10,  subdiv.  1(b),  required  his  admission  to  a 
state-operated treatment program within 48 hours of his detention in Stearns County.  His 
admission was delayed well beyond that 48-hour period.  When Mr. Dalen was detained 
originally, the statute required his admission to a treatment facility “within 48 hours.”  
Minn. Stat. § 253B.10, subdiv. 1(b) (2022).  It seems every court to have decided the 
question understood this 48-hour period to run beginning on entry of a commitment order.  
Not quite two months into Mr. Dalen’s detention, the statute was amended to say that the 
48-hour period begins to run when a state official determines “a medically appropriate bed 

is available.”  2023 Minn. Laws c. 61, art. 4, § 7.                       
In this case removed from Dakota County District Court, Mr. Dalen asserts several 
federal  and  state  claims—including  claims  under  the  United  States  and  Minnesota 
Constitutions—on his behalf and on behalf of a proposed class of individuals who, like Mr. 
Dalen, have been injured by violations of the 48-hour rule.  There may be more to the case, 

but as I understand it, Mr. Dalen seeks damages arising from the Commissioner’s violation 
of the 48-hour rule’s earlier version and an injunction halting implementation of the 
amended version.                                                          
Two motions require a decision.  (1) The Commissioner has moved to dismiss the 
case on jurisdictional and merits grounds, and (2) Mr. Dalen seeks to preliminarily enjoin 

implementation of the 48-hour rule’s 2023 amendment pending entry of final judgment in 
this case.1  The Commissioner’s motion will be granted in part.  Though the better answer 
at this stage is that Mr. Dalen has Article III standing to bring this case, his federal claims 
are not plausibly alleged, and they will be dismissed without prejudice for failure to state 
a claim.  Primarily for this same reason, and because he has not shown a likelihood of 

irreparable harm, Mr. Dalen’s motion for a preliminary injunction will be denied.  Mr. 
Dalen will be given the opportunity to file a second amended complaint.  If he chooses not 

1    Mr. Dalen filed his motion for a preliminary injunction five days after briefing was 
completed on the Commissioner’s Rule 12 motion.  See ECF Nos. 11, 25, and 26. 
to pursue that course, the federal claims will be dismissed with prejudice, judgment will be 
entered, and the case will be remanded to Dakota County District Court for adjudication of 
Mr. Dalen’s claims under Minnesota law.                                   

                           I                                         

                Minn. Stat. § 253B.10, subdiv. 1                     

Section 253B.10 is central to Mr. Dalen’s claims, so it helps to describe it up front.  
The  statute  generally  describes  procedures  to  be  followed  when  a  person  is  civilly 
committed.  It requires that, when a person is civilly committed, “the court shall issue a 
warrant or an order committing the patient to the custody of the head of the treatment 
facility,  state-operated  treatment  program,  or  community-based  treatment  program.”  
Minn. Stat. § 253B.10, subdiv. 1(a).                                      
The statute requires the Commissioner to “prioritize patients being admitted from 
jail or a correctional institution” who fall into any of four categories: (1) persons “ordered 
confined in a state-operated treatment program for” a competency examination under 
Minnesota Rule of Criminal Procedure 20.01; (2) persons “under civil commitment for 
competency treatment and continuing supervision” after being found incompetent to stand 
trial, see Minn. R. Crim. P. Rule 20.01, subdiv. 7; (3) persons “found not guilty by reason 
of mental illness” pursuant to Minnesota Rule of Criminal Procedure 20.02, subdivision 8, 

and who are either “under civil commitment or are ordered to be detained in a state-
operated treatment program pending completion of the civil commitment proceedings”; or 
(4) persons who are civilly committed “after dismissal of the [person’s] criminal charges.”  
Minn. Stat. § 253B.10, subdiv. 1(b)(1)–(4).                               
Of central significance here, the statute establishes a deadline by which persons who 
fall into any of these four categories must be admitted to a state-operated treatment 
program.  In view of the recent statutory amendment, this deadline’s history deserves some 

explanation.                                                              
Beginning July 1, 2013, the statute required that persons described in any of the four 
prioritized-admission  categories  “must  be  admitted  to  a  service  operated  by  the 
commissioner within 48 hours.”  2013 Minn. Laws c. 108, art. 4, § 11.  Prior to July 1, 
2013, the law contained no such deadline; the law did not prioritize admission of civilly 

committed patients from a jail or correctional institution.  See id.  The statute was amended 
in 2020 to specify that admission “within 48 hours” must be “to a state-operated treatment 
program.”  2020 Minn. Laws c. 2, art. 6, § 60.  Minnesota state courts have interpreted the 
48-hour deadline’s original 2013 version as beginning to run when a court entered the 
“warrant or an order committing the patient” as required by the first sentence of Minn. Stat. 

§ 253B.10, subdiv. 1.  Swope v. Harpstead, No. 70-CV-22-13153, Index No. 109 (First 
Judicial Dist., Scott Cnty. Feb. 22, 2023) (“When reading sections (a) and (b) together, it 
is unequivocal that a patient must be admitted within 48-hours [sic] of the Court issuing a 
warrant or order committing the patient to the Commissioner.  The statute is not susceptible 
to more than one reasonable interpretation, it is not ambiguous, and it must be interpreted 

according to its plain meaning.”); Ly v. Harpstead, No. 70-CV-22-13781, Index No. 65 
(First Judicial Dist. Scott Cnty. Dec. 21, 2022) (“When reading subdivision 1(b) in light of 
subdivision 1(a), the clear and unequivocal relevant time marker for the 48 hours is from 
the time of commitment, when the court issues the warrant or order committing the patient 
under  subdivision  1(a).    Therefore,  the  statute  is  not  susceptible  to  more  than  one 
reasonable interpretation, and so the statute is interpreted according to its plain meaning 
without resorting to the canons of construction.”), appeal dismissed, No. A22-1826, 
2023 WL 2661371
 (Minn. Ct. App. Feb. 7, 2023), review granted, (Minn. May 31, 2023); see 
In the Matter of the Civil Commitments of Christodoulou, Elm, and Hassan, Nos. A17-
1312,  1314,  and  1315,  
2018 WL 1145892
,  at  *1  (Minn.  Ct.  App.  Mar.  5,  2018) 
(understanding the 48-hour rule as running from date of commitment and not when 
treatment facilities first become available).  If there are cases interpreting the 48-hour rule’s 

original 2013 version to begin running based on a different, later event, the Commissioner 
has not cited them.  Nor has independent research located such a case.    
During  the  2023  regular  session,  the  legislature  amended  the  48-hour  rule  in 
§ 253B.10, subdiv. 1.  As amended, the statute includes a new subsection (e) that reads: 
“Patients  described  in  paragraph  (b)  must  be  admitted  to  a  state-operated  treatment 

program within 48 hours of the Office of Medical Director, under section 246.018, or a 
designee determining that a medically appropriate bed is available.  This paragraph expires 
on June 30, 2025.”  2023 Minn. Laws c. 61, art. 4, § 7.  The amendment deleted the prior 
version  of  the  48-hour  rule  that  appeared  at  the  end  of  subdivision  1(b).   Id.    The 
amendment was effective May 25, 2023.  See Chairse v. Minn. Dep’t of Hum. Servs., No. 

23-cv-355 (ECT/ECW), 
2023 WL 5984251
, at *2 (D. Minn. Sept. 14, 2023) (explaining 
determination of amendment’s effective date).  According to Mr. Dalen, this amendment 
was intended to counter criticism and legal challenges arising from the Commissioner’s 
failure to comply with the 48-hour rule’s 2013 version.  Am. Compl. [ECF No. 10] ¶¶ 5–
10.                                                                       
                           II                                        

              Relevant Facts Regarding Mr. Dalen                     
Mr. Dalen’s central allegation is that he—among numerous others in Minnesota—
was injured by a violation of the 48-hour rule.  That is, Mr. Dalen claims to have been 
jailed while under a commitment order falling within one of the four prioritized-patient 
categories of § 253B.10, subdiv.1(b), and he claims the Commissioner failed to admit him 

to  a  state-operated  treatment  program  within  48  hours  of  the  court’s  entry  of  his 
commitment order.  The operative Amended Complaint alleges this theory generally in 
several paragraphs.  See Am. Compl. ¶¶ 1, 6, 8, 12, 16, 39.               
The Amended Complaint alleges facts specifically regarding Mr. Dalen in one 
paragraph:                                                                

     Plaintiff Kyle[] Dalen is an individual and a resident of Dakota 
     County,  Minnesota.    Mr.  Dalen  suffers  from  antisocial    
     personality  disorder,  narcissistic  personality  disorder,  and 
     chemical dependency.  Mr. Dalen was initially committed to      
     the custody of the Commissioner by a November 3, 2022, court    
     order.  On April 4, 2023—while Mr. Dalen was still committed    
     to the Commissioner’s custody—he was arrested, jailed, and      
     charged in Stearns County criminal file No. 73-CR-23-2528.      
     Mr. Dalen had not received any treatment since the court’s      
     November  3  order.    Following  an  April  28,  2023,         
     recommitment hearing, the court issued an order for continued   
     commitment.  Neither commitment order was appealed.  Mr.        
     Dalen was only recently admitted to a state operated treatment  
     program.                                                        

Am. Compl. ¶ 3.                                                           
In response to questions raised at the hearing on these motions and in light of the 
parties’ disagreement regarding the precise facts of Mr. Dalen’s commitment, the parties 
submitted a joint letter summarizing state-court proceedings involving Mr. Dalen.  See Ltr. 

to Dist. Judge [ECF No. 40].  The facts described in this letter appear to have been taken 
from public court records and, for this reason, are appropriately considered in adjudicating 
the Commissioner’s Rule 12(b)(6) motion.  See C.H. Robinson Worldwide, Inc. v. Lobrano, 
695 F.3d 758, 764
 (8th Cir. 2012); Noble Sys. Corp. v. Alorica Cent., LLC, 
543 F.3d 978, 983
 (8th Cir. 2008).  The letter identifies three court cases relevant to Mr. Dalen’s claims 

in this case.  The following descriptions of those three cases are drawn from the parties’ 
joint letter; quoted statements appear in quotations in the parties’ letter and are understood 
to have been taken from court records.                                    
(1) On May 20, 2021, Mr. Dalen was charged in Itasca County District Court (No. 
31-CR-21-1240) with one count of harassment and one count of violating a harassment 

restraining  order.    In  October  2021,  the  court  found  reason  to  doubt  Mr.  Dalen’s 
competency and ordered an examination under Minn. R. Crim. P. 20.01.  The parties do 
not say whether Mr. Dalen was ordered confined in a state-operated treatment program for 
this examination.  See Minn. Stat. § 253B.10, subdiv. 1(b)(1).  In January 2022, the court 
found  that  Mr.  Dalen  was  “mentally  ill  so  as  to  be  incapable  of  understanding  the 

proceedings against him or participating in his defense.”  The court determined, however, 
that Mr. Dalen “[did] not present an imminent risk of serious physical harm to himself or 
others,”  and  ordered  Mr.  Dalen  “released  pending  commitment  hearing”  subject  to 
conditions.  In May 2022, Mr. Dalen violated those release conditions and was re-arrested.  
On June 29, 2022, the court again found reason to doubt Mr. Dalen’s competency to 
proceed.  The court ordered that Mr. Dalen undergo “a civil commitment examination 
under Minnesota Statutes section 253B” but also found that, subject to certain conditions, 

Mr. Dalen “is entitled to release, and the examination can be done on an outpatient basis.”  
This criminal case was then suspended under Minnesota Rule of Criminal Procedure 20.01, 
subdiv. 6(b).  Based on the parties’ description, it does not appear the court ever issued a 
warrant or order in this case committing Mr. Dalen under § 253B.10.       
(2) On November 9, 2022, the Itasca County District Court (No. 31-PR-22-2358) 

issued an order committing Mr. Dalen to the Commissioner’s custody and to the head of a 
licensed  substance-use-disorder  treatment  facility  as  “a  mentally  ill  and  chemically 
dependent person.”  The court found that Mr. Dalen met the criteria for a “person who 
poses a risk of harm due to a mental illness,” as defined in Minn. Stat. § 253B.02, subd. 
17a.  The court ordered Mr. Dalen to “fully cooperate in applying for recommended 

treatment or admission to recommended treatment programs or facilities.”  Though neither 
the Amended Complaint nor the parties’ joint letter says so explicitly, I infer from these 
allegations that, following the entry of this commitment order, Mr. Dalen remained “under 
continuing supervision” pursuant to Minn. R. Crim. P. 20.01, subdiv. 7, in the Itasca 
County District Court criminal case described in the preceding paragraph.  On May 4, 2023, 

the commitment court found that Mr. Dalen had been “unwilling to establish outpatient 
mental health care for either therapy or psychiatric medication management.”  The court 
continued Mr. Dalen’s civil commitment for six months.  The commitment order was 
terminated on October 30, 2023.                                           
(3) On March 29, 2023—following entry of the commitment order in the Itasca 
County District Court commitment proceeding described in the preceding paragraph and 
while that order remained in place—Mr. Dalen was charged in Stearns County District 

Court (No. 73-CR-23-2528) with three felony counts of harassment and stalking.  On 
April 3, 2023, Mr. Dalen was arrested on these charges and booked into the Stearns County 
Jail.  Over two months later, on June 6, 2023, the Commissioner admitted Mr. Dalen to the 
Anoka-Metro Regional Treatment Center.  Roughly one month later, on July 5, 2023, Mr. 
Dalen was provisionally discharged from treatment and ordered by the Itasca County 

District Court to be returned to Stearns County Jail.  Mr. Dalen subsequently pleaded guilty 
to two counts of gross misdemeanor harassment.  He was sentenced on October 3, 2023. 
Putting all of this together, it seems plausible to infer from the Amended Complaint 
and the parties’ joint letter that the 48-hour-rule violation Mr. Dalen alleges to have 
suffered occurred as follows: (1) On November 9, 2022, the Itasca County District Court 

in  No.  31-PR-22-2358  issued  an  order  committing  Mr.  Dalen  to  the  custody  of  the 
Commissioner and the head of a treatment program within the meaning of Minn. Stat. 
§ 253B.10, subdiv. 1(a).  (2) The November 9 commitment order subjected Mr. Dalen to 
“continuing supervision” in the Itasca County District Court criminal case (No. 31-CR-21-
1240) pursuant to Minn. R. Crim. P. 20.1, subdiv. 7.  (3) So, when Mr. Dalen was arrested 

and jailed in the Stearns County District Court criminal case (No. 73-CR-23-2528), he  was 
a prioritized patient by operation of Minn. Stat. § 253B.10, subdiv. 1(b)(2), meaning the 
Commissioner was required to admit him “to a state-operated treatment program within 48 
hours” under § 253B.10, subdiv. 1(b).2                                    
                          III                                        

                        This Case                                    
Mr. Dalen brought this case originally in the State of Minnesota District Court, 
Dakota County.  See Notice of Removal [ECF No. 1] ¶ 1; see also Summons and Compl. 
[ECF  No.  1-2].    Owing  to  the  presence  of  claims  arising  under  federal  law,  the 
Commissioner removed the case to this Court in June 2023.  See generally Notice of 

Removal.  Mr. Dalen asserts nine claims in his Amended Complaint.  As I understand them, 
Mr. Dalen’s claims fall into either or both of two categories.  In one category are damages 
claims arising from the Commissioner’s alleged violation of the 48-hour rule’s original 
2013 version with respect to Mr. Dalen.  In the second category are claims challenging the 
lawfulness of the 2023 amendment to the 48-hour rule.                     

Mr.  Dalen’s  nine  claims  are  as  follows:  (1)  Mr.  Dalen  claims  that  the  2023 
amendment to the 48-hour rule is unconstitutionally vague in violation of due-process 
protections provided by the Fourteenth Amendment to the United States Constitution and 
the Minnesota Constitution.  Am. Compl. ¶¶ 24–30.  (2) Mr. Dalen claims that the 2023 
amendment to the 48-hour rule violates separation-of-powers principles under the United 

States  and  Minnesota  Constitutions.    Id.  ¶¶  31–35.    In  Mr.  Dalen’s  understanding, 
“[w]hether a criminal defendant should undergo competency evaluation or treatment prior 

2    If this is not correct, and if it matters to the decisions on the parties’ motions, the 
parties are invited to file a letter pursuant to D. Minn. L.R. 7.1(j).    
to pleading or being tried is a determination relegated [sic] to the judicial branch under 
constitutional precedent and rules of criminal procedure.”  Id. ¶ 32.  (3) Mr. Dalen seeks 
damages  through  
42 U.S.C. § 1983
  arising  from  the  Commissioner’s  deliberate 

indifference to his serious medical needs in violation of the Fourteenth Amendment to the 
United States Constitution.  
Id.
 ¶¶ 36–41.  (4) Mr. Dalen seeks damages through § 1983 
arising from the Commissioner’s imposition of pretrial punishment on Mr. Dalen in 
violation of due-process principles under the United States and Minnesota Constitutions.  
Id.  ¶¶  42–50.    (5)  Mr.  Dalen  seeks  damages  through  §  1983  arising  from  the 

Commissioner’s imposition of unreasonable bodily restraints on Mr. Dalen in violation of 
due-process principles under the United States and Minnesota Constitutions.  Id. ¶¶ 51–58.  
(6) Mr. Dalen seeks damages through § 1983 arising from the Commissioner’s violation 
of substantive-due-process rights guaranteed Mr. Dalen under the Fourteenth Amendment 
to the United States Constitution.  Id. ¶¶ 59–67.  (7) Mr. Dalen asserts an intentional-

infliction-of-emotional-distress claim under Minnesota common law.  Id. ¶¶ 68–73  (8) Mr. 
Dalen asserts a negligent-infliction-of-emotional-distress claim under Minnesota common 
law.  Id. ¶¶ 74–80.  (9) Mr. Dalen claims false imprisonment under Minnesota common 
law.  Id. ¶¶ 81–84.  On his behalf and on behalf of putative class members, I understand 
Mr.  Dalen  to  seek  damages  and  perhaps  also  equitable  relief  with  respect  to  the 

Commissioner’s  alleged  violations  of  the  original  2013  version  of  the  48-hour  rule, 
declaratory and injunctive relief preventing implementation of the 2023 amendment to the 
48-hour rule, and attorneys’ fees and costs.  See id. at 18, ¶¶ A–H.      
                          IV                                         
           Subject-Matter Jurisdiction/Article III Injury            
The presence of claims “arising under the Constitution [and] laws . . . of the United 

States”  ordinarily  means  a  federal  court  has  subject-matter  jurisdiction  over  a  case.  
28 U.S.C. § 1331
.  To support removal, the Commissioner represented that this case fits 
that ordinary rule based on Mr. Dalen’s assertion of claims under § 1983 and the United 
States Constitution.  See Notice of Removal ¶¶ 7–8.  The Commissioner also alleged the 
presence of supplemental jurisdiction over Mr. Dalen’s state-law claims.  Id. ¶¶ 9–10.  

Now, however, the Commissioner argues there is not subject-matter jurisdiction over the 
case.  This is because, in the Commissioner’s view, Mr. Dalen lacks Article III standing—
specifically, Article III injury—to challenge the 48-hour rule’s 2023 amended version.  See 
Def.’s Mem. in Supp. [ECF No. 13] at 6–7.  As presented by the Commissioner, this 
contention is not persuasive.                                             

“A court deciding a motion under Rule 12(b)(1) must distinguish between a ‘facial 
attack’ and a ‘factual attack.’”  Osborn v. United States, 
918 F.2d 724
, 729 n.6 (8th Cir. 
1990) (citations omitted).  “In a facial attack, the court merely needs to look and see if 
plaintiff has sufficiently alleged a basis of subject matter jurisdiction.”  Branson Label, Inc. 
v. City of Branson, 
793 F.3d 910, 914
 (8th Cir. 2015) (cleaned up).  “Conversely, in a 

factual attack, the existence of subject matter jurisdiction is challenged in fact, irrespective 
of the pleadings, and matters outside the pleadings . . . are considered.”  
Id.
 at 914–15 
(cleaned up).  Here, all we have are the Amended Complaint’s allegations and public 
records embraced by the pleading, C.H. Robinson Worldwide, Inc., 
695 F.3d at 764
; Noble 
Sys. Corp., 
543 F.3d at 983
, meaning the Article III standing question the Commissioner 
has identified amounts to a facial attack.                                
To establish Article III standing against a facial attack, the operative pleading must 

allege facts plausibly showing that the plaintiff has “(1) suffered an injury in fact, (2) that 
is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be 
redressed by a favorable judicial decision.”  Spokeo, Inc. v. Robins, 
578 U.S. 330, 338
 
(2016); see also Thole v. U.S. Bank N.A., 590 U.S. ---, 
140 S. Ct. 1615, 1621
 (2020) (noting 
that these elements must be “plausibly and clearly allege[d]”); Lujan v. Defs. of Wildlife, 

504 U.S. 555, 561
 (1992) (citation omitted).3  “In assessing a plaintiff’s Article III standing, 
we must ‘assume that on the merits the plaintiffs would be successful in their claims.’”  
Am. Farm Bureau Fed’n v. United States Env’t Prot. Agency, 
836 F.3d 963, 968
 (8th Cir. 
2016) (quoting Muir v. Navy Fed. Credit Union, 
529 F.3d 1100, 1105
 (D.C. Cir. 2008)). 
The Supreme Court has explained in some detail what makes an injury “concrete” 

for Article III’s purposes.  See, e.g., Ramirez, 594 U.S. at 424–29.  A “concrete” injury is 
“real, and not abstract.”  Spokeo, 
578 U.S. at 340
 (cleaned up).  Complaints that allege 

3    I don’t think it matters, but the ordinarily important and easy-to-answer question of 
who has the burden to show the presence of subject-matter jurisdiction is not so easy to 
answer here.  In the usual case, “the party invoking federal jurisdiction” has the burden to 
show Article III standing.  TransUnion LLC v. Ramirez, 
594 U.S. 413
, 430–31 (2021) 
(citing Lujan, 
504 U.S. at 561
).  In this case, that would be the Commissioner because she 
removed the case to federal court.  Kokkonen v. Guardian Life Ins. Co. of Am., 
511 U.S. 375, 377
 (1994); Baker v. Martin Marietta Materials, Inc., 
745 F.3d 919, 923
 (8th Cir. 
2014).  The Commissioner’s standing argument is not consistent with her removal of the 
case.  Regardless, “[l]ack of subject matter jurisdiction cannot be ignored by the court or 
waived by the parties.”  Johnson v. Welsh Equip., Inc., 
518 F. Supp. 2d 1080, 1085
 (D. 
Minn. 2007).  The Commissioner’s argument will be considered without regard to which 
party bears the burden to establish the presence of Mr. Dalen’s Article III injury.  
“economic or physical harms” are almost always no-doubters.  Hein v. Freedom from 
Religion Found., Inc., 
551 U.S. 587, 642
 (2007) (Souter, J., dissenting).  This is true even 
if the alleged harm is “only a few pennies.”  Wallace v. ConAgra Foods, Inc., 
747 F.3d 1025, 1029
 (8th Cir. 2014).  “When the suit is one challenging the legality of government 
action or inaction” and “the plaintiff is himself an object of the action (or forgone action) 
at issue . . . , there is ordinarily little question that the action or inaction has caused him 
injury, and that a judgment preventing or requiring the action will redress it.”  Lujan, 504 
U.S. at 561–62.                                                           

Here, Mr. Dalen alleges facts plausibly showing that he suffered injury for Article 
III’s purposes.  As noted, Mr. Dalen claims to have suffered injury capable of redress 
through damages owing to the Commissioner’s alleged failure to comply with the 2013 
version of the 48-hour rule.  At least at the level of describing his injuries, this theory is 
not complicated.  Mr. Dalen claims the Commissioner’s violation left him to “languish” in 

the Stearns County Jail for several weeks without the treatment he requires to address his 
mental illness and chemical dependency.  Am. Compl. ¶¶ 1, 3; see Ltr. to Dist. Judge at 2 
(describing Mr. Dalen’s Stearns County confinement).  It is easy to see how Mr. Dalen (or 
anyone like him) would plausibly suffer injuries in this situation.  And, while Mr. Dalen 
was jailed in Stearns County, the 48-hour rule’s 2023 version became effective, meaning 

Mr. Dalen was subjected to what he alleges was an unconstitutional enactment.  See Lujan, 
504 U.S. at 561–62.                                                       
Though there is room for misunderstanding, I understand the Commissioner to 
advance essentially two arguments to show the absence of Article III injury.  First, the 
Commissioner argues that Mr. Dalen has not alleged any injury arising from the 2023 
amended version of the 48-hour rule.  Mem. in Supp. at 6–7.  This is not correct.  Mr. Dalen 
alleges to have been jailed from April 3, 2023, through June 6, 2023, meaning he was 

subject to both the 48-hour rule’s original 2013 version (from April 3 to May 24) and the 
amended 2023 version (from May 25 to his admission to Anoka-Metro Regional Treatment 
Center on June 6).  And he claims to have suffered injury under both versions including at 
least damages arising from the Commissioner’s failure to comply with the 48-hour rule’s 
2013 version and injury from being subjected to the assertedly unconstitutional 2023 

amended version.  Second, the Commissioner  argues  that  Mr.  Dalen’s  injuries  were 
caused—not by her inaction or action with respect to either version of the 48-hour rule—
but by Mr. Dalen’s failure to post bail.  Id. at 7.  There are several reasons to reject this 
argument.  At this point, it is enough to observe that no record evidence shows whether 
Mr. Dalen had the ability to post bail, meaning this argument would require speculating 

about that fact.4                                                         


4    One issue not addressed by the parties deserves mention.  A plaintiff only has 
standing to seek prospective injunctive and declaratory relief when he faces an ongoing 
injury or a “real and immediate” threat of future injury.  City of Los Angeles v. Lyons, 
461 U.S. 95
, 101–05, 107 n.8 (1983).  The Amended Complaint alleges that Mr. Dalen suffers 
from  ongoing  mental  illness  and  chemical  dependency  and  leaves  the  impression—
especially in view of his commitment and criminal records—that he faces some ongoing 
risk of further civil commitment and jailing.  Whether this is enough to show the “real and 
immediate”  threat  required  by  Lyons  is  not  clear.    Regardless,  I  infer  from  the 
Commissioner’s  decision  not  to  raise  this  question  that  she  believes  the  Amended 
Complaint’s allegations are sufficient and perhaps that an answer likely would depend on 
a factual record we don’t have.  For the time being, this issue will therefore be left 
unaddressed.                                                              
                           V                                         

         The Governing Standards and Order of Operations             
         Regarding the Rule 12(b)(6) and Rule 65 Motions             

The standards governing the Commissioner’s motion to dismiss under Rule 12(b)(6) 
are familiar.  In reviewing a motion to dismiss for failure to state a claim under Rule 
12(b)(6), a court must accept as true all of the factual allegations in the complaint and draw 
all reasonable inferences in the plaintiff’s favor.  Gorog v. Best Buy Co. Inc., 
760 F.3d 787, 792
 (8th Cir. 2014) (citation omitted).  Although the factual allegations need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative level.”  Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must “state a claim to 
relief that is plausible on its face.”  
Id. at 570
.  “A claim has facial plausibility when the 
plaintiff pleads factual content that allows the court to draw the reasonable inference that 
the defendant is liable for the misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 
(2009).                                                                   
The standards governing Mr. Dalen’s motion for a preliminary injunction also are 
familiar.  A preliminary injunction is an “extraordinary remedy.”  Winter v. Nat. Res. Def. 

Council, Inc., 
555 U.S. 7, 24
 (2008) (citation omitted).  “In deciding whether to issue a 
preliminary injunction, the district court considers four factors: ‘(1) the threat of irreparable 
harm to the movant; (2) the state of the balance between this harm and the injury that 
granting the injunction will inflict on other parties litigant; (3) the probability that [the] 
movant will succeed on the merits; and (4) the public interest.’”  Sleep No. Corp. v. Young, 

33 F.4th 1012, 1016
 (8th Cir. 2022) (quoting Dataphase Sys., Inc. v. C L Sys., Inc., 
640 F.2d 109, 113
 (8th Cir. 1981) (en banc)).  The core question is whether the equities “so 
favor[] the movant that justice requires the court to intervene to preserve the status quo 
until the merits are determined.”  Dataphase, 
640 F.2d at 113
 (footnote omitted).  “The 

burden of establishing the four factors lies with the party seeking injunctive relief.”  CPI 
Card Grp., Inc. v. Dwyer, 
294 F. Supp. 3d 791, 807
 (D. Minn. 2018) (citing Watkins Inc. 
v. Lewis, 
346 F.3d 841, 844
 (8th Cir. 2003)).  “While no single factor is determinative, the 
probability of success factor is the most significant.”  Home Instead, Inc. v. Florance, 
721 F.3d 494, 497
 (8th Cir. 2013) (cleaned up); Sleep No. Corp., 
33 F.4th at 1016
. 

Here, it makes better sense to begin with the Commissioner’s Rule 12(b)(6) motion.  
Answering whether the Amended Complaint alleges a plausible claim or claims may 
answer—and will at least inform—whether Mr. Dalen is likely to prevail on the merits of 
one or more of his claims.  To account for the chance that Mr. Dalen’s state-law claims 
may be remanded pursuant to 
28 U.S.C. § 1367
(c), Mr. Dalen’s federal claims will be 

considered first in the order they appear in the Amended Complaint.       
                          VI                                         
                           A                                         
             Count I – Void-for-Vagueness Challenge                  
Relying on the Fourteenth Amendment’s Due Process Clause, Mr. Dalen claims that 

the 2023 amendment to § 253B.10, subdiv. 1, is void for vagueness.  Am. Compl. ¶¶ 24–
30.  “The void-for-vagueness doctrine reflects the principle that a statute which either 
forbids  or  requires  the  doing  of  an  act  in  terms  so  vague  that  persons  of  common 
intelligence must necessarily guess at its meaning and differ as to its application, violates 
the first essential of due process of law.”  Roberts v. U.S. Jaycees, 
468 U.S. 609, 629
 (1984) 
(cleaned up).  A statute is void for vagueness if it either “fails to provide a person of 
ordinary intelligence fair notice of what is prohibited,” or “it is so standardless that it 

authorizes or encourages seriously discriminatory enforcement.”  United States v. Paul, 
885 F.3d 1099, 1105
 (8th Cir. 2018) (quoting United States v. Cook, 
782 F.3d 983, 987
 
(8th Cir. 2015).  “[T]he doctrine guards against arbitrary or discriminatory law enforcement 
by insisting that a statute provide standards to govern the actions of police officers, 
prosecutors, juries, and judges.”  Sessions v. Dimaya, 584 U.S. ---, 
138 S. Ct. 1204, 1212
 

(2018) (citing Kolender v. Lawson, 
461 U.S. 352
, 357–358 (1983)).  “In that sense, the 
doctrine is a corollary of the separation of powers—requiring that [the legislature], rather 
than the executive or judicial branch, define what conduct is sanctionable and what is not.”  
Id.
 (citation omitted).  Particularly relevant here, a law is not void for vagueness because it 
requires  the  exercise  of  medical  (or  other  professional)  judgment.    United  States  v. 

Birbragher, 
603 F.3d 478, 489
 (8th Cir. 2010) (holding that the phrase “usual scope of 
professional practice” “has an objective meaning that prevents arbitrary prosecution and 
conviction: Neither the government nor the jury is free to impose its own subjective views 
about what is and is not appropriate; rather, the government is obliged to prove, and the 
jury constrained to determine, what the medical profession would generally do in the 

circumstances”); United States v. Robinson, 
253 F. Supp. 3d 1
, 2–4 (D.D.C. 2017) (finding 
that standards including “legitimate medical purpose” and “usual course of . . . professional 
practice”  were  not  unconstitutionally  vague);  see  Patch  v.  Posusta,  No.  06-cv-0409 
(PJS/JJG), 
2007 WL 3455002
, at *4 (D. Minn. Nov. 14, 2007) (“The enforcement of most 
laws requires the exercise of discretion; lawmakers are not clairvoyant, and it is impossible, 
in  a  law  of  general  applicability,  to  address  with  surgical  precision  every  possible 
circumstance to which the law might apply.”).5                            

The 2023 amendment to § 253B.10, subdiv. 1, is not impermissibly vague.  To 
recap, under the amendment, a prioritized patient like Mr. Dalen “must be admitted to a 
state-operated treatment program within 48 hours of the Office of Medical Director, under 
section 246.018, or a designee determining that a medically appropriate bed is available.”  
Minn. Stat. § 253B.10, subdiv. 1(e).  Section 246.018 establishes and defines the duties of 

the Office of Medical Director.  
Minn. Stat. § 246.018
.  The Medical Director “must be a 
psychiatrist certified by the Board of Psychiatry.”  
Id.,
 subdiv. 2.  The Medical Director 
must also be “licensed.”  
Id.
  If a criminal law that establishes “usual scope of medical 
practice” as the standard is not unconstitutionally vague, Birbragher, 
603 F.3d at 489
, it is 
difficult to see how the “medically appropriate” determination required in § 246.018 would 

be.  And, as the Commissioner points out, this standard appears in many Minnesota 
statutes, see Mem. in Supp. at 10, implying the standard has widespread understanding, 
certainly among physicians and health-care professionals.  No case has been cited or 
identified through independent research holding or implying that this or a comparable 
standard is or might be impermissibly vague.  It is not clear whether Mr. Dalen challenges 

the standard’s “availability” component.  Regardless, this aspect of the standard would 

5    The parties dispute whether the challenged statute should receive lesser scrutiny 
because it is a civil, not a criminal, statute.  See Dimaya, 
138 S. Ct. at 1212
.  Because the 
challenged statute survives the standard applied to criminal statutes, this dispute need not 
be resolved.                                                              
appear  to  require  answering  a  reasonably  clear  question  regarding  the  inventory  of 
available, medically appropriate beds.  For these purely legal reasons, then, Count I will be 
dismissed.                                                                

                           B                                         
            Count II – Separation of Powers Challenge                
Mr. Dalen claims that the 2023 amendment to § 253B.10, subdiv. 1, violates 
separation-of-powers  principles.    Am.  Compl.  ¶¶  31–35.    The  Amended  Complaint 
identifies no particular federal (or state) constitutional provision, doctrine, or line of cases 

on which the claim might be based.  Not that it had to.  See Fed. R. Civ. P. 8(a)(2).  
However, in his brief opposing the Commissioner’s Rule 12(b)(6) motion, Mr. Dalen relies 
on only the Minnesota Constitution to support this claim.  See Pl.’s Mem. in Opp’n [ECF 
No. 22] at 12–15.  He cites no federal constitutional rule or other federal authority.  
Therefore, to the extent this claim was intended originally to rely on the United States 

Constitution or some other federal legal principle, I understand that federal aspect of the 
claim to have been waived.  See Fiecke-Stifter v. MidCountry Bank, No. 22-cv-3056 
(ECT/DTS), 
2023 WL 5844758
, at *8 n.4 (D. Minn. Sept. 11, 2023).          
                           C                                         
            Count III – Deliberate Indifference Claim                

Mr. Dalen alleges the Commissioner failed to provide him with adequate medical 
care in violation of the Fourteenth Amendment’s Due Process Clause.  Am. Compl. ¶¶ 36–
41.  The Eighth Amendment’s deliberate-indifference standard applies to a Fourteenth 
Amendment claim alleging deficient medical care brought by a pretrial detainee or civilly 
committed person.  Leonard v. St. Charles Cnty. Police Dep’t, 
59 F.4th 355, 360
 (8th Cir. 
2023) (pretrial detainee); Mead v. Palmer, 
794 F.3d 932, 936
 (8th Cir. 2015) (civil 
committee).  As the court explained in Leonard:                           

     “[D]eliberate  indifference  is  a  difficult  standard  to  meet.”  
     Spencer v. Knapheide Truck Equip., Co., 
183 F.3d 902, 906
       
     (8th Cir. 1999).  It requires an official to consciously disregard 
     a known and “objectively serious medical need.”  Schaub v.      
     VonWald,  
638 F.3d 905, 914
  (8th  Cir.  2011).    A  serious 
     medical need is one diagnosed by a physician or “so obvious     
     that  even  a  layman  would  recognize  [it].”    
Id.
  (citation 
     omitted).  And the disregard for it must rise to the level of   
     criminal recklessness.  Jackson v. Buckman, 
756 F.3d 1060, 1066
 (8th Cir. 2014); see Estelle [v. Gamble], 429 U.S. [97,]   
     105–06  .  .  .  [(1976)].    Only  then  is  the  failure  to  act  a 
     “punishment[].”  Estelle, 429 U.S. at 102–06 . . .; see U.S.    
     Const. amend. VIII.                                             

59 F.4th at 360
; see Karsjens v. Lourey, 
988 F.3d 1047, 1052
 (8th Cir. 2021) (Karsjens II) 
(recognizing that the Eighth Amendment requires a plaintiff to show that the defendant 
“knew about excessive risks to [the plaintiff’s] health but disregarded them, and that [those] 
unconstitutional actions in fact caused his injuries”) (quotation omitted). 
The Amended Complaint does not allege facts plausibly showing that Mr. Dalen 
suffered from excessive risks to his health or that the Commissioner knew about these risks 
when Mr. Dalen was detained in the Stearns County Jail.  The pleading’s description of 
Mr. Dalen’s health is not specific to this period.  It alleges generally that Mr. Dalen “suffers 
from  antisocial  personality  disorder,  narcissistic  personality  disorder,  and  chemical 
dependency.”  Am. Compl. ¶ 3.  We know that Mr. Dalen was under a civil commitment 
order beginning November 9, 2022.  Ltr. to Dist. Judge at 2.  But Mr. Dalen was not arrested 
and detained in Stearns County until April 3, 2023, and the pleading includes no description 
of his condition or medical needs at that time.  It is no doubt true that health conditions 
prompting  a  person’s  civil  commitment  might  be  so  severe  and  pervasive  that  a 
commitment order itself might establish the presence and scope of an objectively serious 

medical need for some indefinite, prolonged period.  The allegations do not show that this 
is true with respect to Mr. Dalen.  There is no particular description of the Itasca County 
District Court’s commitment order, but that court does not seem to have ordered that Mr. 
Dalen be detained in connection with his civil commitment.  
Id.
  With respect to the 
Commissioner’s  knowledge  of  Mr.  Dalen’s  medical  needs,  the  Amended  Complaint 

alleges that she “actually knew about these needs because she receives court orders placing 
Plaintiff and Class members in her custody for examination and treatment of those needs.”  
Am. Compl. ¶ 38.  Without allegations regarding the content of Mr. Dalen’s commitment 
order, it is difficult to understand how the Commissioner might have known of Mr. Dalen’s 
needs.  Regardless, no allegations suggest that the Commissioner knew of Mr. Dalen’s 

medical needs as they might have existed in April 2023, when he was arrested and jailed 
in Stearns County.                                                        
                           D                                         
             Count IV – Pretrial Punishment Claim                    
Mr. Dalen alleges “[t]he conditions of county jails and state prisons are severely 

detrimental to the safety and wellbeing of individuals who suffer from disorders and 
dependencies like” Mr. Dalen and members of the proposed class he seeks to represent, so 
much that “their confinement is punitive.”  Am. Compl. ¶¶ 45, 46.  Mr. Dalen alleges, 
therefore, that the Commissioner’s “refusal to timely remove Plaintiff and Class members 
from such conditions therefore constitutes punishment absent a criminal conviction in 
violation of the Constitution.”  Id. ¶ 48.  In the Eighth Circuit, the standard announced in 
Bell v. Wolfish, 
441 U.S. 520, 535
 (1979), applies to conditions-of-confinement claims 

brought by pretrial detainees and civilly committed persons.  Karsjens II, 988 F.3d at 1052–
53.  “In analyzing whether a condition of confinement is punitive, courts ‘decide whether 
the disability is imposed for the purpose of punishment or whether it is but an incident of 
some other legitimate governmental purpose.’”  
Id.
 at 1052 (quoting Bell, 
441 U.S. at 538
).  
A detainee may meet this standard in two ways: (1) the detainee may show that challenged 

conditions were intentionally punitive; and (2) absent an intent to punish, a detainee may 
“show that the conditions were not reasonably related to a legitimate governmental purpose 
or were excessive in relation to that purpose.”  Stearns v. Inmate Servs. Corp., 
957 F.3d 902, 907
 (8th Cir. 2020).                                                 
This claim is not plausibly alleged.  It is not clear what conditions are being 

challenged.  The Amended Complaint alleges Mr. Dalen was detained, but it does not 
allege the conditions of his confinement.  In other words, the pleading lacks allegations 
plausibly showing either that Mr. Dalen’s Stearns County confinement conditions were 
intentionally punitive or excessive in some way particular to him.  If Mr. Dalen’s theory of 
this claim is that confinement in a jail is per se or always unconstitutionally punitive for 

persons who are under a civil commitment order, the Amended Complaint must allege facts 
showing  why  this  is  plausibly  so.    Apart  from  describing  the  policy  justifications 
underlying the 48-hour rule, the pleading does not address this question.  In his opposition 
brief, Mr. Dalen cites the Amended Complaint’s allegations that conditions of incarceration 
generally are harmful in comparison to treatment for persons subject to a civil commitment 
order.  See Pl.’s Mem. in Opp’n at 18 (citing Am. Compl. ¶¶ 3, 13, 45, 56, 77, 78).  This 
assertion, accepted as true, does not plausibly show that jail conditions encountered by Mr. 

Dalen or civilly committed persons generally either lack any reasonable relationship to a 
legitimate government purpose or are excessive in relation to such a purpose.  Finally, it 
seems worth noting that accepting Mr. Dalen’s theory would necessitate holding that every 
civilly committed person jailed on criminal charges is, by virtue of their civilly committed 
status, subject to punitive confinement conditions.  No case or other authority has been 

cited or independently identified that might support this theory.         
                           E                                         

            Count V – Unreasonable Restraints Claim                  

Mr.  Dalen  alleges  the  Commissioner  “abridged  Plaintiff  and  Class  members’ 
freedom from bodily restraint.”  Am. Compl. ¶ 54; see 
id.
 ¶¶ 51–58.  “[I]nvoluntarily civilly 
committed persons hold a protected liberty interest to be free from unnecessary bodily 
restraint.”  Montin v. Gibson, 
718 F.3d 752
, 754–55 (8th Cir. 2013) (citing Youngberg v. 
Romeo, 
457 U.S. 307
, 320–22 (1982)).  A “professional-judgment test” is applied to assess 
the constitutionality of a bodily restraint.  
Id.
 at 755 (quoting Youngberg, 
457 U.S. at 321
).  
Under this test, “great deference is owed to the professional judgment of a qualified 
professional charged with balancing the plaintiff’s freedom from bodily restraint against 
the safety of the public, the plaintiff, and other patients.”  
Id.
        
This claim is not plausibly alleged.  The Amended Complaint alleges no facts 
describing whether or how Mr. Dalen or any potential class member was bodily restrained 
in a relevant sense.  All we are told is that Mr. Dalen and potential class members were 
jailed following their arrest on criminal charges.  Mr. Dalen fairly cites cases holding that 
an  unreasonable-restraint  claim  may  apply  “to  conditions  beyond  actual  physical 

restraints.”  Pl.’s Mem. in Opp’n at 24.  Though some of the cases Mr. Dalen cites do not 
support the stated proposition,6 the propositions that an unconstitutional restraint may take 
varied forms and that Youngberg’s professional-judgment standard might apply to evaluate 
a Fourteenth Amendment challenge to varied forms of restraint seem noncontroversial.  
Regardless, Mr. Dalen cites no authority to support the idea that pretrial detention in a jail 

without anything more is a “restraint” susceptible to Youngberg analysis.  The absence of 
allegations in the Amended Complaint showing either what professional judgment was 
exercised with respect to Mr. Dalen’s Stearns County jailing or how this judgment fails to 
meet appropriate professional standards confirms the point.               





6    For example, Mr. Dalen cites United States v. Holmes, 
900 F.2d 1322
 (8th Cir. 
1990)  (Mem.),  for  the  proposition  that  Youngberg’s  professional-judgment  standard 
applies to claims challenging forcible medication.  Pl.’s Mem. in Opp’n at 24.  Whether 
that proposition is correct, Holmes does not support it.  The case does not cite Youngberg, 
apply its standard, or say that the standard applies to forced-medication claims.  
900 F.2d at 1322
.  As another example, Mr. Dalen cites Arnzen v. Palmer, 
713 F.3d 369
 (8th Cir. 
2013), for the proposition that the Youngberg standard applies to judge the constitutionality 
of security cameras placed in bathrooms at a sex-offender treatment facility.  Pl.’s Mem. 
in Opp’n at 24.  Not so.  In Arnzen, the Eighth Circuit noted that the district court had 
applied Youngberg to analyze the claim.  
713 F.3d at 372
.  But the Eighth Circuit analyzed 
the  claim  as  a  search  under  the  Fourth  Amendment  and  nowhere  characterized  the 
placement of cameras as a “restraint” to be analyzed under the Fourteenth Amendment.  
See 
id.
 at 372–75.                                                        
                           F                                         

            Count VI – Substantive Due Process Claim                 

Mr. Dalen alleges the Commissioner violated his and potential class members’ 
Fourteenth Amendment substantive-due-process rights by detaining them “in the jails and 
prisons with knowledge that they would likely suffer severe mental and physical injuries” 
and by “lobbying, either individually and/or through counsel,” for the 2023 amendment to 
§ 253B.10, subdiv. 1.  Am. Compl. ¶¶ 64, 65.  As the Eighth Circuit has explained: 
     In  addition  to  its  procedural  protections,  the  Due  Process 
     Clause protects individual liberties from government action     
     “regardless of the fairness of the procedures used to implement 
     them.”  Mills v. City of Grand Forks, 
614 F.3d 495, 498
 (8th    
     Cir.  2010)  (internal  quotation  marks  omitted).    To  state  a 
     substantive due process claim against a state official, a plaintiff 
     must demonstrate that a fundamental right was violated and      
     that the official’s conduct shocks the conscience.  Folkerts v. 
     City of Waverly, 
707 F.3d 975, 980
 (8th Cir. 2013).  Whether    
     conduct  shocks  the  conscience  is  a  question  of  law.    
Id.
  
     Conscience shocking conduct only includes “the most severe      
     violations of individual rights that result from the brutal and 
     inhumane abuse of official power.”  White v. Smith, 
696 F.3d 740
, 757–58 (8th Cir. 2012) (quotation marks omitted).  “Only   
     a purpose to cause harm unrelated to the legitimate object of   
     the government action in question will satisfy the element of   
     arbitrary conduct shocking to the conscience, necessary for a   
     due process violation.”  Folkerts, 
707 F.3d at 981
 (cleaned up). 

Mitchell v. Dakota Cnty. Soc. Servs., 
959 F.3d 887, 898
 (8th Cir. 2020).  A fundamental 
right is one that is “objectively, ‘deeply rooted in this Nation’s history and tradition.’” 
Washington v. Glucksberg, 
521 U.S. 702
, 720–21 (1997) (quoting Moore v. City of E. 
Cleveland, 
431 U.S. 494, 503
 (1977)).                                     
Here, the Amended Complaint does not allege facts plausibly showing the violation 
of a fundamental right or conscience-shocking conduct.  Mr. Dalen disavows claiming “a 
fundamental substantive due process right to treatment in an inpatient setting.”  Pl.’s Mem. 

in Opp’n at 27 n.7.  He alleges no facts addressing whether § 253B.10, subdiv. 1’s 48-hour 
rule, or a like concept, is “deeply rooted in this Nation’s history and tradition.”  Glucksberg, 
521 U.S. at 720–21.  A hypothetical failure to comply with the 48-hour rule might plausibly 
be  conscience-shocking  depending  on  the  failure’s  duration  and  perhaps  other 
considerations, but the Amended Complaint alleges no facts showing or implying that Mr. 

Dalen’s Stearns County detention was conscience-shocking in any respect specific to it.  
The Amended Complaint takes a different approach.  It appears to contend that every 
decision  to  detain  someone  who  is  civilly  committed  beyond  48  hours  is 
conscience-shocking, see Am. Compl. ¶¶ 64–65, but it contains no factual allegations that 
would plausibly support that categorical assertion.  Mr. Dalen cites no authority holding 

that a state official’s successful legislative advocacy might trigger a substantive-due-
process violation.                                                        
                          VII                                        
               The Preliminary Injunction Motion                     
Regarding Mr. Dalen’s motion for a preliminary injunction, the absence of merit to 

Mr. Dalen’s federal claims means he is not likely to prevail with respect to his § 1983 
damages claims or his claims challenging the 2023 amendment to § 253B.10, subdiv. 1.  
Mr.  Dalen  neither  distinguishes  his  state  constitutional  claims  from  his  federal 
constitutional  claims  nor  relies  on  his  state  tort  damages  claims  to  challenge 
implementation of the amendment.                                          
Nor has Mr. Dalen shown that he is likely to suffer irreparable harm.  As Mr. Dalen 

notes in his supporting brief, he has been admitted to a treatment facility.  See Pl.’s Mem. 
in Supp. [ECF No. 28] at 4.  Mr. Dalen identifies no particular ongoing threat that he will 
be charged with another crime and jailed while under a commitment order, and the 
likelihood of an unnamed potential class member being jailed while civilly committed 
cannot justify the issuance of an injunction in Mr. Dalen’s favor.        

The last two factors are the balance of the relative harms and the public interest.  For 
practical purposes, these factors “merge” when a plaintiff seeks injunctive relief against 
the government.  Nken v. Holder, 
556 U.S. 418, 435
 (2009); see Angelica C. v. Immigr. & 
Customs Enf’t, No. 20-cv-913 (NEB/ECW), 
2020 WL 3441461
, at *17 (D. Minn. June 5, 
2020), report and recommendation adopted, 
2020 WL 3429945
 (D. Minn. June 23, 2020).  

Now that he is receiving treatment, the harm Mr. Dalen might suffer in the absence of an 
injunction seems unclear and probably remote.  Public interest considerations do not clearly 
favor either party, but boil down to competing, sincerely held policy concerns that—absent 
a constitutional problem—the legislature is best positioned to assess.  See Let Them Play 
MN v. Walz, 
517 F. Supp. 3d 870
, 888 (D. Minn. 2021).                     

                          VIII                                       
               Where This Case Goes From Here                        
A district court “may decline to exercise supplemental jurisdiction over a claim . . . 
if . . . the district court has dismissed all claims over which it has original jurisdiction.”  
28 U.S.C. § 1367
(c)(3).  “[I]n the usual case in which all federal-law claims are eliminated 
before  trial,  the  balance  of  factors  to  be  considered  under  the  pendent  jurisdiction 
doctrine—judicial  economy,  convenience,  fairness,  and  comity—will  point  toward 

declining to exercise jurisdiction over the remaining state-law claims.”  Barstad v. Murray 
Cnty., 
420 F.3d 880, 888
 (8th Cir. 2005) (quoting Carnegie–Mellon Univ. v. Cohill, 
484 U.S. 343
, 350 n.7 (1988)).  And the Eighth Circuit has instructed district courts not to 
exercise supplemental jurisdiction over state-law claims when, as here, all federal claims 
are dismissed well before trial.  See Hervey v. Cnty. of Koochiching, 
527 F.3d 711
, 726–

27 (8th Cir. 2008).  Thus, without more, the dismissal of Mr. Dalen’s federal claims, 
combined with the absence of diversity jurisdiction under 
28 U.S.C. § 1332
(a), would 
prompt the with-prejudice dismissal of the federal claims, the entry of judgment on those 
claims, and remand of Mr. Dalen’s state claims to Dakota County District Court. 
Notwithstanding these principles, Mr. Dalen has asked that any dismissal be without 

prejudice.  Mr. Dalen represents that any dismissed claims might conceivably be repleaded 
with success.  This is because, as Mr. Dalen describes things, “new facts surrounding 
Defendant’s misconduct continue to become available, including Defendant failing to 
admit committed individuals even more than 48 hours after determining that a medically 
appropriate bed is available.”  Pl.’s Mem. in Opp’n at 42.  In view of Mr. Dalen’s request 

and these representations, the better answer is to allow Mr. Dalen the opportunity to file an 
amended  pleading  in  which  he  may  attempt  to  cure  the  dismissal-worthy  problems 
described in this order and perhaps allege additional facts discovered after briefing was 
closed on these motions.  Mr. Dalen’s federal constitutional claims will therefore be 
dismissed without prejudice, and Mr. Dalen will be given a deadline by which to file a 
Second Amended Complaint.  If he opts not file a Second Amended Complaint by the 
prescribed deadline, his federal constitutional claims will be dismissed with prejudice, 

judgment will be entered as to those claims, and the case will be remanded to Dakota 
County District Court.  Judgment will be entered at this time only with respect to the denial 
of Mr. Dalen’s motion for a preliminary injunction.                       

ORDER

Therefore, based upon the foregoing, and on all of the files, records, and proceedings 

herein, IT IS ORDERED THAT:                                               
1.   Defendant Jodi Harpstead’s Motion to Dismiss [ECF No. 11] is GRANTED 
IN PART.  Plaintiff Kyle Jerome Dalen’s claims arising under 
42 U.S.C. § 1983
 and/or 
the United States Constitution are DISMISSED WITHOUT PREJUDICE.           
2.   On or before February 6, 2024, Plaintiff Kyle Jerome Dalen may file a second 

amended complaint.  If no second amended complaint is filed by that deadline, judgment 
will be entered dismissing Mr. Dalen’s claims arising under 
42 U.S.C. § 1983
 and/or the 
United States Constitution with prejudice and the case will be remanded to Dakota County 
District Court for the reasons described in this Order.                   
3.   Plaintiff Kyle Jerome Dalen’s Motion for Preliminary Injunction [ECF No. 

26] is DENIED.                                                            
       LET JUDGMENT BE ENTERED ACCORDINGLY.                          

Date: January 16, 2024             s/ Eric C. Tostrud                     
                              Eric C. Tostrud                        
                              United States District Court           

Trial Court Opinion

             UNITED STATES DISTRICT COURT                            
                DISTRICT OF MINNESOTA                                


Kyle Jerome Dalen, individually and on    File No. 23-cv-1877 (ECT/ECW)   
behalf of all others similarly situated,                                  

     Plaintiff,                                                      

v.                                       OPINION AND ORDER                

Jodi Harpstead, Commissioner of the                                       
Minnesota Department of Human Services,                                   
in her individual and official capacities,                                

     Defendant.                                                      


Daniel E. Gustafson, David A. Goodwin, Anthony J. Stauber, and Joseph E. Nelson, 
Gustafson Gluek PLLC, Minneapolis, MN; Kevin J. Wetherille and James P. Conway, 
Jaspers Moriarty & Wetherille, P.A., Shakopee, MN; Jason D. Gustafson, Throndset 
Michenfelder Law Office, LLC, St. Michael, MN, and Hannah L. Scheidecker, Fremstad 
Law, Fargo, ND, for Plaintiff Kyle Jerome Dalen.                          

Aaron Winter and Sparrowleaf Dilts McGregor, Office of the Minnesota Attorney General, 
St. Paul, MN, for Defendant Jodi Harpstead.                               


Plaintiff Kyle Jerome Dalen was under a civil commitment order while in the 
custody of a Minnesota county jail facing criminal charges.  Mr. Dalen claims that a 
Minnesota  statute,  Minn.  Stat.  §  253B.10,  subdiv.  1(b),  required  his  admission  to  a 
state-operated treatment program within 48 hours of his detention in Stearns County.  His 
admission was delayed well beyond that 48-hour period.  When Mr. Dalen was detained 
originally, the statute required his admission to a treatment facility “within 48 hours.”  
Minn. Stat. § 253B.10, subdiv. 1(b) (2022).  It seems every court to have decided the 
question understood this 48-hour period to run beginning on entry of a commitment order.  
Not quite two months into Mr. Dalen’s detention, the statute was amended to say that the 
48-hour period begins to run when a state official determines “a medically appropriate bed 

is available.”  2023 Minn. Laws c. 61, art. 4, § 7.                       
In this case removed from Dakota County District Court, Mr. Dalen asserts several 
federal  and  state  claims—including  claims  under  the  United  States  and  Minnesota 
Constitutions—on his behalf and on behalf of a proposed class of individuals who, like Mr. 
Dalen, have been injured by violations of the 48-hour rule.  There may be more to the case, 

but as I understand it, Mr. Dalen seeks damages arising from the Commissioner’s violation 
of the 48-hour rule’s earlier version and an injunction halting implementation of the 
amended version.                                                          
Two motions require a decision.  (1) The Commissioner has moved to dismiss the 
case on jurisdictional and merits grounds, and (2) Mr. Dalen seeks to preliminarily enjoin 

implementation of the 48-hour rule’s 2023 amendment pending entry of final judgment in 
this case.1  The Commissioner’s motion will be granted in part.  Though the better answer 
at this stage is that Mr. Dalen has Article III standing to bring this case, his federal claims 
are not plausibly alleged, and they will be dismissed without prejudice for failure to state 
a claim.  Primarily for this same reason, and because he has not shown a likelihood of 

irreparable harm, Mr. Dalen’s motion for a preliminary injunction will be denied.  Mr. 
Dalen will be given the opportunity to file a second amended complaint.  If he chooses not 

1    Mr. Dalen filed his motion for a preliminary injunction five days after briefing was 
completed on the Commissioner’s Rule 12 motion.  See ECF Nos. 11, 25, and 26. 
to pursue that course, the federal claims will be dismissed with prejudice, judgment will be 
entered, and the case will be remanded to Dakota County District Court for adjudication of 
Mr. Dalen’s claims under Minnesota law.                                   

                           I                                         

                Minn. Stat. § 253B.10, subdiv. 1                     

Section 253B.10 is central to Mr. Dalen’s claims, so it helps to describe it up front.  
The  statute  generally  describes  procedures  to  be  followed  when  a  person  is  civilly 
committed.  It requires that, when a person is civilly committed, “the court shall issue a 
warrant or an order committing the patient to the custody of the head of the treatment 
facility,  state-operated  treatment  program,  or  community-based  treatment  program.”  
Minn. Stat. § 253B.10, subdiv. 1(a).                                      
The statute requires the Commissioner to “prioritize patients being admitted from 
jail or a correctional institution” who fall into any of four categories: (1) persons “ordered 
confined in a state-operated treatment program for” a competency examination under 
Minnesota Rule of Criminal Procedure 20.01; (2) persons “under civil commitment for 
competency treatment and continuing supervision” after being found incompetent to stand 
trial, see Minn. R. Crim. P. Rule 20.01, subdiv. 7; (3) persons “found not guilty by reason 
of mental illness” pursuant to Minnesota Rule of Criminal Procedure 20.02, subdivision 8, 

and who are either “under civil commitment or are ordered to be detained in a state-
operated treatment program pending completion of the civil commitment proceedings”; or 
(4) persons who are civilly committed “after dismissal of the [person’s] criminal charges.”  
Minn. Stat. § 253B.10, subdiv. 1(b)(1)–(4).                               
Of central significance here, the statute establishes a deadline by which persons who 
fall into any of these four categories must be admitted to a state-operated treatment 
program.  In view of the recent statutory amendment, this deadline’s history deserves some 

explanation.                                                              
Beginning July 1, 2013, the statute required that persons described in any of the four 
prioritized-admission  categories  “must  be  admitted  to  a  service  operated  by  the 
commissioner within 48 hours.”  2013 Minn. Laws c. 108, art. 4, § 11.  Prior to July 1, 
2013, the law contained no such deadline; the law did not prioritize admission of civilly 

committed patients from a jail or correctional institution.  See id.  The statute was amended 
in 2020 to specify that admission “within 48 hours” must be “to a state-operated treatment 
program.”  2020 Minn. Laws c. 2, art. 6, § 60.  Minnesota state courts have interpreted the 
48-hour deadline’s original 2013 version as beginning to run when a court entered the 
“warrant or an order committing the patient” as required by the first sentence of Minn. Stat. 

§ 253B.10, subdiv. 1.  Swope v. Harpstead, No. 70-CV-22-13153, Index No. 109 (First 
Judicial Dist., Scott Cnty. Feb. 22, 2023) (“When reading sections (a) and (b) together, it 
is unequivocal that a patient must be admitted within 48-hours [sic] of the Court issuing a 
warrant or order committing the patient to the Commissioner.  The statute is not susceptible 
to more than one reasonable interpretation, it is not ambiguous, and it must be interpreted 

according to its plain meaning.”); Ly v. Harpstead, No. 70-CV-22-13781, Index No. 65 
(First Judicial Dist. Scott Cnty. Dec. 21, 2022) (“When reading subdivision 1(b) in light of 
subdivision 1(a), the clear and unequivocal relevant time marker for the 48 hours is from 
the time of commitment, when the court issues the warrant or order committing the patient 
under  subdivision  1(a).    Therefore,  the  statute  is  not  susceptible  to  more  than  one 
reasonable interpretation, and so the statute is interpreted according to its plain meaning 
without resorting to the canons of construction.”), appeal dismissed, No. A22-1826, 
2023 WL 2661371
 (Minn. Ct. App. Feb. 7, 2023), review granted, (Minn. May 31, 2023); see 
In the Matter of the Civil Commitments of Christodoulou, Elm, and Hassan, Nos. A17-
1312,  1314,  and  1315,  
2018 WL 1145892
,  at  *1  (Minn.  Ct.  App.  Mar.  5,  2018) 
(understanding the 48-hour rule as running from date of commitment and not when 
treatment facilities first become available).  If there are cases interpreting the 48-hour rule’s 

original 2013 version to begin running based on a different, later event, the Commissioner 
has not cited them.  Nor has independent research located such a case.    
During  the  2023  regular  session,  the  legislature  amended  the  48-hour  rule  in 
§ 253B.10, subdiv. 1.  As amended, the statute includes a new subsection (e) that reads: 
“Patients  described  in  paragraph  (b)  must  be  admitted  to  a  state-operated  treatment 

program within 48 hours of the Office of Medical Director, under section 246.018, or a 
designee determining that a medically appropriate bed is available.  This paragraph expires 
on June 30, 2025.”  2023 Minn. Laws c. 61, art. 4, § 7.  The amendment deleted the prior 
version  of  the  48-hour  rule  that  appeared  at  the  end  of  subdivision  1(b).   Id.    The 
amendment was effective May 25, 2023.  See Chairse v. Minn. Dep’t of Hum. Servs., No. 

23-cv-355 (ECT/ECW), 
2023 WL 5984251
, at *2 (D. Minn. Sept. 14, 2023) (explaining 
determination of amendment’s effective date).  According to Mr. Dalen, this amendment 
was intended to counter criticism and legal challenges arising from the Commissioner’s 
failure to comply with the 48-hour rule’s 2013 version.  Am. Compl. [ECF No. 10] ¶¶ 5–
10.                                                                       
                           II                                        

              Relevant Facts Regarding Mr. Dalen                     
Mr. Dalen’s central allegation is that he—among numerous others in Minnesota—
was injured by a violation of the 48-hour rule.  That is, Mr. Dalen claims to have been 
jailed while under a commitment order falling within one of the four prioritized-patient 
categories of § 253B.10, subdiv.1(b), and he claims the Commissioner failed to admit him 

to  a  state-operated  treatment  program  within  48  hours  of  the  court’s  entry  of  his 
commitment order.  The operative Amended Complaint alleges this theory generally in 
several paragraphs.  See Am. Compl. ¶¶ 1, 6, 8, 12, 16, 39.               
The Amended Complaint alleges facts specifically regarding Mr. Dalen in one 
paragraph:                                                                

     Plaintiff Kyle[] Dalen is an individual and a resident of Dakota 
     County,  Minnesota.    Mr.  Dalen  suffers  from  antisocial    
     personality  disorder,  narcissistic  personality  disorder,  and 
     chemical dependency.  Mr. Dalen was initially committed to      
     the custody of the Commissioner by a November 3, 2022, court    
     order.  On April 4, 2023—while Mr. Dalen was still committed    
     to the Commissioner’s custody—he was arrested, jailed, and      
     charged in Stearns County criminal file No. 73-CR-23-2528.      
     Mr. Dalen had not received any treatment since the court’s      
     November  3  order.    Following  an  April  28,  2023,         
     recommitment hearing, the court issued an order for continued   
     commitment.  Neither commitment order was appealed.  Mr.        
     Dalen was only recently admitted to a state operated treatment  
     program.                                                        

Am. Compl. ¶ 3.                                                           
In response to questions raised at the hearing on these motions and in light of the 
parties’ disagreement regarding the precise facts of Mr. Dalen’s commitment, the parties 
submitted a joint letter summarizing state-court proceedings involving Mr. Dalen.  See Ltr. 

to Dist. Judge [ECF No. 40].  The facts described in this letter appear to have been taken 
from public court records and, for this reason, are appropriately considered in adjudicating 
the Commissioner’s Rule 12(b)(6) motion.  See C.H. Robinson Worldwide, Inc. v. Lobrano, 
695 F.3d 758, 764
 (8th Cir. 2012); Noble Sys. Corp. v. Alorica Cent., LLC, 
543 F.3d 978, 983
 (8th Cir. 2008).  The letter identifies three court cases relevant to Mr. Dalen’s claims 

in this case.  The following descriptions of those three cases are drawn from the parties’ 
joint letter; quoted statements appear in quotations in the parties’ letter and are understood 
to have been taken from court records.                                    
(1) On May 20, 2021, Mr. Dalen was charged in Itasca County District Court (No. 
31-CR-21-1240) with one count of harassment and one count of violating a harassment 

restraining  order.    In  October  2021,  the  court  found  reason  to  doubt  Mr.  Dalen’s 
competency and ordered an examination under Minn. R. Crim. P. 20.01.  The parties do 
not say whether Mr. Dalen was ordered confined in a state-operated treatment program for 
this examination.  See Minn. Stat. § 253B.10, subdiv. 1(b)(1).  In January 2022, the court 
found  that  Mr.  Dalen  was  “mentally  ill  so  as  to  be  incapable  of  understanding  the 

proceedings against him or participating in his defense.”  The court determined, however, 
that Mr. Dalen “[did] not present an imminent risk of serious physical harm to himself or 
others,”  and  ordered  Mr.  Dalen  “released  pending  commitment  hearing”  subject  to 
conditions.  In May 2022, Mr. Dalen violated those release conditions and was re-arrested.  
On June 29, 2022, the court again found reason to doubt Mr. Dalen’s competency to 
proceed.  The court ordered that Mr. Dalen undergo “a civil commitment examination 
under Minnesota Statutes section 253B” but also found that, subject to certain conditions, 

Mr. Dalen “is entitled to release, and the examination can be done on an outpatient basis.”  
This criminal case was then suspended under Minnesota Rule of Criminal Procedure 20.01, 
subdiv. 6(b).  Based on the parties’ description, it does not appear the court ever issued a 
warrant or order in this case committing Mr. Dalen under § 253B.10.       
(2) On November 9, 2022, the Itasca County District Court (No. 31-PR-22-2358) 

issued an order committing Mr. Dalen to the Commissioner’s custody and to the head of a 
licensed  substance-use-disorder  treatment  facility  as  “a  mentally  ill  and  chemically 
dependent person.”  The court found that Mr. Dalen met the criteria for a “person who 
poses a risk of harm due to a mental illness,” as defined in Minn. Stat. § 253B.02, subd. 
17a.  The court ordered Mr. Dalen to “fully cooperate in applying for recommended 

treatment or admission to recommended treatment programs or facilities.”  Though neither 
the Amended Complaint nor the parties’ joint letter says so explicitly, I infer from these 
allegations that, following the entry of this commitment order, Mr. Dalen remained “under 
continuing supervision” pursuant to Minn. R. Crim. P. 20.01, subdiv. 7, in the Itasca 
County District Court criminal case described in the preceding paragraph.  On May 4, 2023, 

the commitment court found that Mr. Dalen had been “unwilling to establish outpatient 
mental health care for either therapy or psychiatric medication management.”  The court 
continued Mr. Dalen’s civil commitment for six months.  The commitment order was 
terminated on October 30, 2023.                                           
(3) On March 29, 2023—following entry of the commitment order in the Itasca 
County District Court commitment proceeding described in the preceding paragraph and 
while that order remained in place—Mr. Dalen was charged in Stearns County District 

Court (No. 73-CR-23-2528) with three felony counts of harassment and stalking.  On 
April 3, 2023, Mr. Dalen was arrested on these charges and booked into the Stearns County 
Jail.  Over two months later, on June 6, 2023, the Commissioner admitted Mr. Dalen to the 
Anoka-Metro Regional Treatment Center.  Roughly one month later, on July 5, 2023, Mr. 
Dalen was provisionally discharged from treatment and ordered by the Itasca County 

District Court to be returned to Stearns County Jail.  Mr. Dalen subsequently pleaded guilty 
to two counts of gross misdemeanor harassment.  He was sentenced on October 3, 2023. 
Putting all of this together, it seems plausible to infer from the Amended Complaint 
and the parties’ joint letter that the 48-hour-rule violation Mr. Dalen alleges to have 
suffered occurred as follows: (1) On November 9, 2022, the Itasca County District Court 

in  No.  31-PR-22-2358  issued  an  order  committing  Mr.  Dalen  to  the  custody  of  the 
Commissioner and the head of a treatment program within the meaning of Minn. Stat. 
§ 253B.10, subdiv. 1(a).  (2) The November 9 commitment order subjected Mr. Dalen to 
“continuing supervision” in the Itasca County District Court criminal case (No. 31-CR-21-
1240) pursuant to Minn. R. Crim. P. 20.1, subdiv. 7.  (3) So, when Mr. Dalen was arrested 

and jailed in the Stearns County District Court criminal case (No. 73-CR-23-2528), he  was 
a prioritized patient by operation of Minn. Stat. § 253B.10, subdiv. 1(b)(2), meaning the 
Commissioner was required to admit him “to a state-operated treatment program within 48 
hours” under § 253B.10, subdiv. 1(b).2                                    
                          III                                        

                        This Case                                    
Mr. Dalen brought this case originally in the State of Minnesota District Court, 
Dakota County.  See Notice of Removal [ECF No. 1] ¶ 1; see also Summons and Compl. 
[ECF  No.  1-2].    Owing  to  the  presence  of  claims  arising  under  federal  law,  the 
Commissioner removed the case to this Court in June 2023.  See generally Notice of 

Removal.  Mr. Dalen asserts nine claims in his Amended Complaint.  As I understand them, 
Mr. Dalen’s claims fall into either or both of two categories.  In one category are damages 
claims arising from the Commissioner’s alleged violation of the 48-hour rule’s original 
2013 version with respect to Mr. Dalen.  In the second category are claims challenging the 
lawfulness of the 2023 amendment to the 48-hour rule.                     

Mr.  Dalen’s  nine  claims  are  as  follows:  (1)  Mr.  Dalen  claims  that  the  2023 
amendment to the 48-hour rule is unconstitutionally vague in violation of due-process 
protections provided by the Fourteenth Amendment to the United States Constitution and 
the Minnesota Constitution.  Am. Compl. ¶¶ 24–30.  (2) Mr. Dalen claims that the 2023 
amendment to the 48-hour rule violates separation-of-powers principles under the United 

States  and  Minnesota  Constitutions.    Id.  ¶¶  31–35.    In  Mr.  Dalen’s  understanding, 
“[w]hether a criminal defendant should undergo competency evaluation or treatment prior 

2    If this is not correct, and if it matters to the decisions on the parties’ motions, the 
parties are invited to file a letter pursuant to D. Minn. L.R. 7.1(j).    
to pleading or being tried is a determination relegated [sic] to the judicial branch under 
constitutional precedent and rules of criminal procedure.”  Id. ¶ 32.  (3) Mr. Dalen seeks 
damages  through  
42 U.S.C. § 1983
  arising  from  the  Commissioner’s  deliberate 

indifference to his serious medical needs in violation of the Fourteenth Amendment to the 
United States Constitution.  
Id.
 ¶¶ 36–41.  (4) Mr. Dalen seeks damages through § 1983 
arising from the Commissioner’s imposition of pretrial punishment on Mr. Dalen in 
violation of due-process principles under the United States and Minnesota Constitutions.  
Id.  ¶¶  42–50.    (5)  Mr.  Dalen  seeks  damages  through  §  1983  arising  from  the 

Commissioner’s imposition of unreasonable bodily restraints on Mr. Dalen in violation of 
due-process principles under the United States and Minnesota Constitutions.  Id. ¶¶ 51–58.  
(6) Mr. Dalen seeks damages through § 1983 arising from the Commissioner’s violation 
of substantive-due-process rights guaranteed Mr. Dalen under the Fourteenth Amendment 
to the United States Constitution.  Id. ¶¶ 59–67.  (7) Mr. Dalen asserts an intentional-

infliction-of-emotional-distress claim under Minnesota common law.  Id. ¶¶ 68–73  (8) Mr. 
Dalen asserts a negligent-infliction-of-emotional-distress claim under Minnesota common 
law.  Id. ¶¶ 74–80.  (9) Mr. Dalen claims false imprisonment under Minnesota common 
law.  Id. ¶¶ 81–84.  On his behalf and on behalf of putative class members, I understand 
Mr.  Dalen  to  seek  damages  and  perhaps  also  equitable  relief  with  respect  to  the 

Commissioner’s  alleged  violations  of  the  original  2013  version  of  the  48-hour  rule, 
declaratory and injunctive relief preventing implementation of the 2023 amendment to the 
48-hour rule, and attorneys’ fees and costs.  See id. at 18, ¶¶ A–H.      
                          IV                                         
           Subject-Matter Jurisdiction/Article III Injury            
The presence of claims “arising under the Constitution [and] laws . . . of the United 

States”  ordinarily  means  a  federal  court  has  subject-matter  jurisdiction  over  a  case.  
28 U.S.C. § 1331
.  To support removal, the Commissioner represented that this case fits 
that ordinary rule based on Mr. Dalen’s assertion of claims under § 1983 and the United 
States Constitution.  See Notice of Removal ¶¶ 7–8.  The Commissioner also alleged the 
presence of supplemental jurisdiction over Mr. Dalen’s state-law claims.  Id. ¶¶ 9–10.  

Now, however, the Commissioner argues there is not subject-matter jurisdiction over the 
case.  This is because, in the Commissioner’s view, Mr. Dalen lacks Article III standing—
specifically, Article III injury—to challenge the 48-hour rule’s 2023 amended version.  See 
Def.’s Mem. in Supp. [ECF No. 13] at 6–7.  As presented by the Commissioner, this 
contention is not persuasive.                                             

“A court deciding a motion under Rule 12(b)(1) must distinguish between a ‘facial 
attack’ and a ‘factual attack.’”  Osborn v. United States, 
918 F.2d 724
, 729 n.6 (8th Cir. 
1990) (citations omitted).  “In a facial attack, the court merely needs to look and see if 
plaintiff has sufficiently alleged a basis of subject matter jurisdiction.”  Branson Label, Inc. 
v. City of Branson, 
793 F.3d 910, 914
 (8th Cir. 2015) (cleaned up).  “Conversely, in a 

factual attack, the existence of subject matter jurisdiction is challenged in fact, irrespective 
of the pleadings, and matters outside the pleadings . . . are considered.”  
Id.
 at 914–15 
(cleaned up).  Here, all we have are the Amended Complaint’s allegations and public 
records embraced by the pleading, C.H. Robinson Worldwide, Inc., 
695 F.3d at 764
; Noble 
Sys. Corp., 
543 F.3d at 983
, meaning the Article III standing question the Commissioner 
has identified amounts to a facial attack.                                
To establish Article III standing against a facial attack, the operative pleading must 

allege facts plausibly showing that the plaintiff has “(1) suffered an injury in fact, (2) that 
is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be 
redressed by a favorable judicial decision.”  Spokeo, Inc. v. Robins, 
578 U.S. 330, 338
 
(2016); see also Thole v. U.S. Bank N.A., 590 U.S. ---, 
140 S. Ct. 1615, 1621
 (2020) (noting 
that these elements must be “plausibly and clearly allege[d]”); Lujan v. Defs. of Wildlife, 

504 U.S. 555, 561
 (1992) (citation omitted).3  “In assessing a plaintiff’s Article III standing, 
we must ‘assume that on the merits the plaintiffs would be successful in their claims.’”  
Am. Farm Bureau Fed’n v. United States Env’t Prot. Agency, 
836 F.3d 963, 968
 (8th Cir. 
2016) (quoting Muir v. Navy Fed. Credit Union, 
529 F.3d 1100, 1105
 (D.C. Cir. 2008)). 
The Supreme Court has explained in some detail what makes an injury “concrete” 

for Article III’s purposes.  See, e.g., Ramirez, 594 U.S. at 424–29.  A “concrete” injury is 
“real, and not abstract.”  Spokeo, 
578 U.S. at 340
 (cleaned up).  Complaints that allege 

3    I don’t think it matters, but the ordinarily important and easy-to-answer question of 
who has the burden to show the presence of subject-matter jurisdiction is not so easy to 
answer here.  In the usual case, “the party invoking federal jurisdiction” has the burden to 
show Article III standing.  TransUnion LLC v. Ramirez, 
594 U.S. 413
, 430–31 (2021) 
(citing Lujan, 
504 U.S. at 561
).  In this case, that would be the Commissioner because she 
removed the case to federal court.  Kokkonen v. Guardian Life Ins. Co. of Am., 
511 U.S. 375, 377
 (1994); Baker v. Martin Marietta Materials, Inc., 
745 F.3d 919, 923
 (8th Cir. 
2014).  The Commissioner’s standing argument is not consistent with her removal of the 
case.  Regardless, “[l]ack of subject matter jurisdiction cannot be ignored by the court or 
waived by the parties.”  Johnson v. Welsh Equip., Inc., 
518 F. Supp. 2d 1080, 1085
 (D. 
Minn. 2007).  The Commissioner’s argument will be considered without regard to which 
party bears the burden to establish the presence of Mr. Dalen’s Article III injury.  
“economic or physical harms” are almost always no-doubters.  Hein v. Freedom from 
Religion Found., Inc., 
551 U.S. 587, 642
 (2007) (Souter, J., dissenting).  This is true even 
if the alleged harm is “only a few pennies.”  Wallace v. ConAgra Foods, Inc., 
747 F.3d 1025, 1029
 (8th Cir. 2014).  “When the suit is one challenging the legality of government 
action or inaction” and “the plaintiff is himself an object of the action (or forgone action) 
at issue . . . , there is ordinarily little question that the action or inaction has caused him 
injury, and that a judgment preventing or requiring the action will redress it.”  Lujan, 504 
U.S. at 561–62.                                                           

Here, Mr. Dalen alleges facts plausibly showing that he suffered injury for Article 
III’s purposes.  As noted, Mr. Dalen claims to have suffered injury capable of redress 
through damages owing to the Commissioner’s alleged failure to comply with the 2013 
version of the 48-hour rule.  At least at the level of describing his injuries, this theory is 
not complicated.  Mr. Dalen claims the Commissioner’s violation left him to “languish” in 

the Stearns County Jail for several weeks without the treatment he requires to address his 
mental illness and chemical dependency.  Am. Compl. ¶¶ 1, 3; see Ltr. to Dist. Judge at 2 
(describing Mr. Dalen’s Stearns County confinement).  It is easy to see how Mr. Dalen (or 
anyone like him) would plausibly suffer injuries in this situation.  And, while Mr. Dalen 
was jailed in Stearns County, the 48-hour rule’s 2023 version became effective, meaning 

Mr. Dalen was subjected to what he alleges was an unconstitutional enactment.  See Lujan, 
504 U.S. at 561–62.                                                       
Though there is room for misunderstanding, I understand the Commissioner to 
advance essentially two arguments to show the absence of Article III injury.  First, the 
Commissioner argues that Mr. Dalen has not alleged any injury arising from the 2023 
amended version of the 48-hour rule.  Mem. in Supp. at 6–7.  This is not correct.  Mr. Dalen 
alleges to have been jailed from April 3, 2023, through June 6, 2023, meaning he was 

subject to both the 48-hour rule’s original 2013 version (from April 3 to May 24) and the 
amended 2023 version (from May 25 to his admission to Anoka-Metro Regional Treatment 
Center on June 6).  And he claims to have suffered injury under both versions including at 
least damages arising from the Commissioner’s failure to comply with the 48-hour rule’s 
2013 version and injury from being subjected to the assertedly unconstitutional 2023 

amended version.  Second, the Commissioner  argues  that  Mr.  Dalen’s  injuries  were 
caused—not by her inaction or action with respect to either version of the 48-hour rule—
but by Mr. Dalen’s failure to post bail.  Id. at 7.  There are several reasons to reject this 
argument.  At this point, it is enough to observe that no record evidence shows whether 
Mr. Dalen had the ability to post bail, meaning this argument would require speculating 

about that fact.4                                                         


4    One issue not addressed by the parties deserves mention.  A plaintiff only has 
standing to seek prospective injunctive and declaratory relief when he faces an ongoing 
injury or a “real and immediate” threat of future injury.  City of Los Angeles v. Lyons, 
461 U.S. 95
, 101–05, 107 n.8 (1983).  The Amended Complaint alleges that Mr. Dalen suffers 
from  ongoing  mental  illness  and  chemical  dependency  and  leaves  the  impression—
especially in view of his commitment and criminal records—that he faces some ongoing 
risk of further civil commitment and jailing.  Whether this is enough to show the “real and 
immediate”  threat  required  by  Lyons  is  not  clear.    Regardless,  I  infer  from  the 
Commissioner’s  decision  not  to  raise  this  question  that  she  believes  the  Amended 
Complaint’s allegations are sufficient and perhaps that an answer likely would depend on 
a factual record we don’t have.  For the time being, this issue will therefore be left 
unaddressed.                                                              
                           V                                         

         The Governing Standards and Order of Operations             
         Regarding the Rule 12(b)(6) and Rule 65 Motions             

The standards governing the Commissioner’s motion to dismiss under Rule 12(b)(6) 
are familiar.  In reviewing a motion to dismiss for failure to state a claim under Rule 
12(b)(6), a court must accept as true all of the factual allegations in the complaint and draw 
all reasonable inferences in the plaintiff’s favor.  Gorog v. Best Buy Co. Inc., 
760 F.3d 787, 792
 (8th Cir. 2014) (citation omitted).  Although the factual allegations need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative level.”  Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must “state a claim to 
relief that is plausible on its face.”  
Id. at 570
.  “A claim has facial plausibility when the 
plaintiff pleads factual content that allows the court to draw the reasonable inference that 
the defendant is liable for the misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 
(2009).                                                                   
The standards governing Mr. Dalen’s motion for a preliminary injunction also are 
familiar.  A preliminary injunction is an “extraordinary remedy.”  Winter v. Nat. Res. Def. 

Council, Inc., 
555 U.S. 7, 24
 (2008) (citation omitted).  “In deciding whether to issue a 
preliminary injunction, the district court considers four factors: ‘(1) the threat of irreparable 
harm to the movant; (2) the state of the balance between this harm and the injury that 
granting the injunction will inflict on other parties litigant; (3) the probability that [the] 
movant will succeed on the merits; and (4) the public interest.’”  Sleep No. Corp. v. Young, 

33 F.4th 1012, 1016
 (8th Cir. 2022) (quoting Dataphase Sys., Inc. v. C L Sys., Inc., 
640 F.2d 109, 113
 (8th Cir. 1981) (en banc)).  The core question is whether the equities “so 
favor[] the movant that justice requires the court to intervene to preserve the status quo 
until the merits are determined.”  Dataphase, 
640 F.2d at 113
 (footnote omitted).  “The 

burden of establishing the four factors lies with the party seeking injunctive relief.”  CPI 
Card Grp., Inc. v. Dwyer, 
294 F. Supp. 3d 791, 807
 (D. Minn. 2018) (citing Watkins Inc. 
v. Lewis, 
346 F.3d 841, 844
 (8th Cir. 2003)).  “While no single factor is determinative, the 
probability of success factor is the most significant.”  Home Instead, Inc. v. Florance, 
721 F.3d 494, 497
 (8th Cir. 2013) (cleaned up); Sleep No. Corp., 
33 F.4th at 1016
. 

Here, it makes better sense to begin with the Commissioner’s Rule 12(b)(6) motion.  
Answering whether the Amended Complaint alleges a plausible claim or claims may 
answer—and will at least inform—whether Mr. Dalen is likely to prevail on the merits of 
one or more of his claims.  To account for the chance that Mr. Dalen’s state-law claims 
may be remanded pursuant to 
28 U.S.C. § 1367
(c), Mr. Dalen’s federal claims will be 

considered first in the order they appear in the Amended Complaint.       
                          VI                                         
                           A                                         
             Count I – Void-for-Vagueness Challenge                  
Relying on the Fourteenth Amendment’s Due Process Clause, Mr. Dalen claims that 

the 2023 amendment to § 253B.10, subdiv. 1, is void for vagueness.  Am. Compl. ¶¶ 24–
30.  “The void-for-vagueness doctrine reflects the principle that a statute which either 
forbids  or  requires  the  doing  of  an  act  in  terms  so  vague  that  persons  of  common 
intelligence must necessarily guess at its meaning and differ as to its application, violates 
the first essential of due process of law.”  Roberts v. U.S. Jaycees, 
468 U.S. 609, 629
 (1984) 
(cleaned up).  A statute is void for vagueness if it either “fails to provide a person of 
ordinary intelligence fair notice of what is prohibited,” or “it is so standardless that it 

authorizes or encourages seriously discriminatory enforcement.”  United States v. Paul, 
885 F.3d 1099, 1105
 (8th Cir. 2018) (quoting United States v. Cook, 
782 F.3d 983, 987
 
(8th Cir. 2015).  “[T]he doctrine guards against arbitrary or discriminatory law enforcement 
by insisting that a statute provide standards to govern the actions of police officers, 
prosecutors, juries, and judges.”  Sessions v. Dimaya, 584 U.S. ---, 
138 S. Ct. 1204, 1212
 

(2018) (citing Kolender v. Lawson, 
461 U.S. 352
, 357–358 (1983)).  “In that sense, the 
doctrine is a corollary of the separation of powers—requiring that [the legislature], rather 
than the executive or judicial branch, define what conduct is sanctionable and what is not.”  
Id.
 (citation omitted).  Particularly relevant here, a law is not void for vagueness because it 
requires  the  exercise  of  medical  (or  other  professional)  judgment.    United  States  v. 

Birbragher, 
603 F.3d 478, 489
 (8th Cir. 2010) (holding that the phrase “usual scope of 
professional practice” “has an objective meaning that prevents arbitrary prosecution and 
conviction: Neither the government nor the jury is free to impose its own subjective views 
about what is and is not appropriate; rather, the government is obliged to prove, and the 
jury constrained to determine, what the medical profession would generally do in the 

circumstances”); United States v. Robinson, 
253 F. Supp. 3d 1
, 2–4 (D.D.C. 2017) (finding 
that standards including “legitimate medical purpose” and “usual course of . . . professional 
practice”  were  not  unconstitutionally  vague);  see  Patch  v.  Posusta,  No.  06-cv-0409 
(PJS/JJG), 
2007 WL 3455002
, at *4 (D. Minn. Nov. 14, 2007) (“The enforcement of most 
laws requires the exercise of discretion; lawmakers are not clairvoyant, and it is impossible, 
in  a  law  of  general  applicability,  to  address  with  surgical  precision  every  possible 
circumstance to which the law might apply.”).5                            

The 2023 amendment to § 253B.10, subdiv. 1, is not impermissibly vague.  To 
recap, under the amendment, a prioritized patient like Mr. Dalen “must be admitted to a 
state-operated treatment program within 48 hours of the Office of Medical Director, under 
section 246.018, or a designee determining that a medically appropriate bed is available.”  
Minn. Stat. § 253B.10, subdiv. 1(e).  Section 246.018 establishes and defines the duties of 

the Office of Medical Director.  
Minn. Stat. § 246.018
.  The Medical Director “must be a 
psychiatrist certified by the Board of Psychiatry.”  
Id.,
 subdiv. 2.  The Medical Director 
must also be “licensed.”  
Id.
  If a criminal law that establishes “usual scope of medical 
practice” as the standard is not unconstitutionally vague, Birbragher, 
603 F.3d at 489
, it is 
difficult to see how the “medically appropriate” determination required in § 246.018 would 

be.  And, as the Commissioner points out, this standard appears in many Minnesota 
statutes, see Mem. in Supp. at 10, implying the standard has widespread understanding, 
certainly among physicians and health-care professionals.  No case has been cited or 
identified through independent research holding or implying that this or a comparable 
standard is or might be impermissibly vague.  It is not clear whether Mr. Dalen challenges 

the standard’s “availability” component.  Regardless, this aspect of the standard would 

5    The parties dispute whether the challenged statute should receive lesser scrutiny 
because it is a civil, not a criminal, statute.  See Dimaya, 
138 S. Ct. at 1212
.  Because the 
challenged statute survives the standard applied to criminal statutes, this dispute need not 
be resolved.                                                              
appear  to  require  answering  a  reasonably  clear  question  regarding  the  inventory  of 
available, medically appropriate beds.  For these purely legal reasons, then, Count I will be 
dismissed.                                                                

                           B                                         
            Count II – Separation of Powers Challenge                
Mr. Dalen claims that the 2023 amendment to § 253B.10, subdiv. 1, violates 
separation-of-powers  principles.    Am.  Compl.  ¶¶  31–35.    The  Amended  Complaint 
identifies no particular federal (or state) constitutional provision, doctrine, or line of cases 

on which the claim might be based.  Not that it had to.  See Fed. R. Civ. P. 8(a)(2).  
However, in his brief opposing the Commissioner’s Rule 12(b)(6) motion, Mr. Dalen relies 
on only the Minnesota Constitution to support this claim.  See Pl.’s Mem. in Opp’n [ECF 
No. 22] at 12–15.  He cites no federal constitutional rule or other federal authority.  
Therefore, to the extent this claim was intended originally to rely on the United States 

Constitution or some other federal legal principle, I understand that federal aspect of the 
claim to have been waived.  See Fiecke-Stifter v. MidCountry Bank, No. 22-cv-3056 
(ECT/DTS), 
2023 WL 5844758
, at *8 n.4 (D. Minn. Sept. 11, 2023).          
                           C                                         
            Count III – Deliberate Indifference Claim                

Mr. Dalen alleges the Commissioner failed to provide him with adequate medical 
care in violation of the Fourteenth Amendment’s Due Process Clause.  Am. Compl. ¶¶ 36–
41.  The Eighth Amendment’s deliberate-indifference standard applies to a Fourteenth 
Amendment claim alleging deficient medical care brought by a pretrial detainee or civilly 
committed person.  Leonard v. St. Charles Cnty. Police Dep’t, 
59 F.4th 355, 360
 (8th Cir. 
2023) (pretrial detainee); Mead v. Palmer, 
794 F.3d 932, 936
 (8th Cir. 2015) (civil 
committee).  As the court explained in Leonard:                           

     “[D]eliberate  indifference  is  a  difficult  standard  to  meet.”  
     Spencer v. Knapheide Truck Equip., Co., 
183 F.3d 902, 906
       
     (8th Cir. 1999).  It requires an official to consciously disregard 
     a known and “objectively serious medical need.”  Schaub v.      
     VonWald,  
638 F.3d 905, 914
  (8th  Cir.  2011).    A  serious 
     medical need is one diagnosed by a physician or “so obvious     
     that  even  a  layman  would  recognize  [it].”    
Id.
  (citation 
     omitted).  And the disregard for it must rise to the level of   
     criminal recklessness.  Jackson v. Buckman, 
756 F.3d 1060, 1066
 (8th Cir. 2014); see Estelle [v. Gamble], 429 U.S. [97,]   
     105–06  .  .  .  [(1976)].    Only  then  is  the  failure  to  act  a 
     “punishment[].”  Estelle, 429 U.S. at 102–06 . . .; see U.S.    
     Const. amend. VIII.                                             

59 F.4th at 360
; see Karsjens v. Lourey, 
988 F.3d 1047, 1052
 (8th Cir. 2021) (Karsjens II) 
(recognizing that the Eighth Amendment requires a plaintiff to show that the defendant 
“knew about excessive risks to [the plaintiff’s] health but disregarded them, and that [those] 
unconstitutional actions in fact caused his injuries”) (quotation omitted). 
The Amended Complaint does not allege facts plausibly showing that Mr. Dalen 
suffered from excessive risks to his health or that the Commissioner knew about these risks 
when Mr. Dalen was detained in the Stearns County Jail.  The pleading’s description of 
Mr. Dalen’s health is not specific to this period.  It alleges generally that Mr. Dalen “suffers 
from  antisocial  personality  disorder,  narcissistic  personality  disorder,  and  chemical 
dependency.”  Am. Compl. ¶ 3.  We know that Mr. Dalen was under a civil commitment 
order beginning November 9, 2022.  Ltr. to Dist. Judge at 2.  But Mr. Dalen was not arrested 
and detained in Stearns County until April 3, 2023, and the pleading includes no description 
of his condition or medical needs at that time.  It is no doubt true that health conditions 
prompting  a  person’s  civil  commitment  might  be  so  severe  and  pervasive  that  a 
commitment order itself might establish the presence and scope of an objectively serious 

medical need for some indefinite, prolonged period.  The allegations do not show that this 
is true with respect to Mr. Dalen.  There is no particular description of the Itasca County 
District Court’s commitment order, but that court does not seem to have ordered that Mr. 
Dalen be detained in connection with his civil commitment.  
Id.
  With respect to the 
Commissioner’s  knowledge  of  Mr.  Dalen’s  medical  needs,  the  Amended  Complaint 

alleges that she “actually knew about these needs because she receives court orders placing 
Plaintiff and Class members in her custody for examination and treatment of those needs.”  
Am. Compl. ¶ 38.  Without allegations regarding the content of Mr. Dalen’s commitment 
order, it is difficult to understand how the Commissioner might have known of Mr. Dalen’s 
needs.  Regardless, no allegations suggest that the Commissioner knew of Mr. Dalen’s 

medical needs as they might have existed in April 2023, when he was arrested and jailed 
in Stearns County.                                                        
                           D                                         
             Count IV – Pretrial Punishment Claim                    
Mr. Dalen alleges “[t]he conditions of county jails and state prisons are severely 

detrimental to the safety and wellbeing of individuals who suffer from disorders and 
dependencies like” Mr. Dalen and members of the proposed class he seeks to represent, so 
much that “their confinement is punitive.”  Am. Compl. ¶¶ 45, 46.  Mr. Dalen alleges, 
therefore, that the Commissioner’s “refusal to timely remove Plaintiff and Class members 
from such conditions therefore constitutes punishment absent a criminal conviction in 
violation of the Constitution.”  Id. ¶ 48.  In the Eighth Circuit, the standard announced in 
Bell v. Wolfish, 
441 U.S. 520, 535
 (1979), applies to conditions-of-confinement claims 

brought by pretrial detainees and civilly committed persons.  Karsjens II, 988 F.3d at 1052–
53.  “In analyzing whether a condition of confinement is punitive, courts ‘decide whether 
the disability is imposed for the purpose of punishment or whether it is but an incident of 
some other legitimate governmental purpose.’”  
Id.
 at 1052 (quoting Bell, 
441 U.S. at 538
).  
A detainee may meet this standard in two ways: (1) the detainee may show that challenged 

conditions were intentionally punitive; and (2) absent an intent to punish, a detainee may 
“show that the conditions were not reasonably related to a legitimate governmental purpose 
or were excessive in relation to that purpose.”  Stearns v. Inmate Servs. Corp., 
957 F.3d 902, 907
 (8th Cir. 2020).                                                 
This claim is not plausibly alleged.  It is not clear what conditions are being 

challenged.  The Amended Complaint alleges Mr. Dalen was detained, but it does not 
allege the conditions of his confinement.  In other words, the pleading lacks allegations 
plausibly showing either that Mr. Dalen’s Stearns County confinement conditions were 
intentionally punitive or excessive in some way particular to him.  If Mr. Dalen’s theory of 
this claim is that confinement in a jail is per se or always unconstitutionally punitive for 

persons who are under a civil commitment order, the Amended Complaint must allege facts 
showing  why  this  is  plausibly  so.    Apart  from  describing  the  policy  justifications 
underlying the 48-hour rule, the pleading does not address this question.  In his opposition 
brief, Mr. Dalen cites the Amended Complaint’s allegations that conditions of incarceration 
generally are harmful in comparison to treatment for persons subject to a civil commitment 
order.  See Pl.’s Mem. in Opp’n at 18 (citing Am. Compl. ¶¶ 3, 13, 45, 56, 77, 78).  This 
assertion, accepted as true, does not plausibly show that jail conditions encountered by Mr. 

Dalen or civilly committed persons generally either lack any reasonable relationship to a 
legitimate government purpose or are excessive in relation to such a purpose.  Finally, it 
seems worth noting that accepting Mr. Dalen’s theory would necessitate holding that every 
civilly committed person jailed on criminal charges is, by virtue of their civilly committed 
status, subject to punitive confinement conditions.  No case or other authority has been 

cited or independently identified that might support this theory.         
                           E                                         

            Count V – Unreasonable Restraints Claim                  

Mr.  Dalen  alleges  the  Commissioner  “abridged  Plaintiff  and  Class  members’ 
freedom from bodily restraint.”  Am. Compl. ¶ 54; see 
id.
 ¶¶ 51–58.  “[I]nvoluntarily civilly 
committed persons hold a protected liberty interest to be free from unnecessary bodily 
restraint.”  Montin v. Gibson, 
718 F.3d 752
, 754–55 (8th Cir. 2013) (citing Youngberg v. 
Romeo, 
457 U.S. 307
, 320–22 (1982)).  A “professional-judgment test” is applied to assess 
the constitutionality of a bodily restraint.  
Id.
 at 755 (quoting Youngberg, 
457 U.S. at 321
).  
Under this test, “great deference is owed to the professional judgment of a qualified 
professional charged with balancing the plaintiff’s freedom from bodily restraint against 
the safety of the public, the plaintiff, and other patients.”  
Id.
        
This claim is not plausibly alleged.  The Amended Complaint alleges no facts 
describing whether or how Mr. Dalen or any potential class member was bodily restrained 
in a relevant sense.  All we are told is that Mr. Dalen and potential class members were 
jailed following their arrest on criminal charges.  Mr. Dalen fairly cites cases holding that 
an  unreasonable-restraint  claim  may  apply  “to  conditions  beyond  actual  physical 

restraints.”  Pl.’s Mem. in Opp’n at 24.  Though some of the cases Mr. Dalen cites do not 
support the stated proposition,6 the propositions that an unconstitutional restraint may take 
varied forms and that Youngberg’s professional-judgment standard might apply to evaluate 
a Fourteenth Amendment challenge to varied forms of restraint seem noncontroversial.  
Regardless, Mr. Dalen cites no authority to support the idea that pretrial detention in a jail 

without anything more is a “restraint” susceptible to Youngberg analysis.  The absence of 
allegations in the Amended Complaint showing either what professional judgment was 
exercised with respect to Mr. Dalen’s Stearns County jailing or how this judgment fails to 
meet appropriate professional standards confirms the point.               





6    For example, Mr. Dalen cites United States v. Holmes, 
900 F.2d 1322
 (8th Cir. 
1990)  (Mem.),  for  the  proposition  that  Youngberg’s  professional-judgment  standard 
applies to claims challenging forcible medication.  Pl.’s Mem. in Opp’n at 24.  Whether 
that proposition is correct, Holmes does not support it.  The case does not cite Youngberg, 
apply its standard, or say that the standard applies to forced-medication claims.  
900 F.2d at 1322
.  As another example, Mr. Dalen cites Arnzen v. Palmer, 
713 F.3d 369
 (8th Cir. 
2013), for the proposition that the Youngberg standard applies to judge the constitutionality 
of security cameras placed in bathrooms at a sex-offender treatment facility.  Pl.’s Mem. 
in Opp’n at 24.  Not so.  In Arnzen, the Eighth Circuit noted that the district court had 
applied Youngberg to analyze the claim.  
713 F.3d at 372
.  But the Eighth Circuit analyzed 
the  claim  as  a  search  under  the  Fourth  Amendment  and  nowhere  characterized  the 
placement of cameras as a “restraint” to be analyzed under the Fourteenth Amendment.  
See 
id.
 at 372–75.                                                        
                           F                                         

            Count VI – Substantive Due Process Claim                 

Mr. Dalen alleges the Commissioner violated his and potential class members’ 
Fourteenth Amendment substantive-due-process rights by detaining them “in the jails and 
prisons with knowledge that they would likely suffer severe mental and physical injuries” 
and by “lobbying, either individually and/or through counsel,” for the 2023 amendment to 
§ 253B.10, subdiv. 1.  Am. Compl. ¶¶ 64, 65.  As the Eighth Circuit has explained: 
     In  addition  to  its  procedural  protections,  the  Due  Process 
     Clause protects individual liberties from government action     
     “regardless of the fairness of the procedures used to implement 
     them.”  Mills v. City of Grand Forks, 
614 F.3d 495, 498
 (8th    
     Cir.  2010)  (internal  quotation  marks  omitted).    To  state  a 
     substantive due process claim against a state official, a plaintiff 
     must demonstrate that a fundamental right was violated and      
     that the official’s conduct shocks the conscience.  Folkerts v. 
     City of Waverly, 
707 F.3d 975, 980
 (8th Cir. 2013).  Whether    
     conduct  shocks  the  conscience  is  a  question  of  law.    
Id.
  
     Conscience shocking conduct only includes “the most severe      
     violations of individual rights that result from the brutal and 
     inhumane abuse of official power.”  White v. Smith, 
696 F.3d 740
, 757–58 (8th Cir. 2012) (quotation marks omitted).  “Only   
     a purpose to cause harm unrelated to the legitimate object of   
     the government action in question will satisfy the element of   
     arbitrary conduct shocking to the conscience, necessary for a   
     due process violation.”  Folkerts, 
707 F.3d at 981
 (cleaned up). 

Mitchell v. Dakota Cnty. Soc. Servs., 
959 F.3d 887, 898
 (8th Cir. 2020).  A fundamental 
right is one that is “objectively, ‘deeply rooted in this Nation’s history and tradition.’” 
Washington v. Glucksberg, 
521 U.S. 702
, 720–21 (1997) (quoting Moore v. City of E. 
Cleveland, 
431 U.S. 494, 503
 (1977)).                                     
Here, the Amended Complaint does not allege facts plausibly showing the violation 
of a fundamental right or conscience-shocking conduct.  Mr. Dalen disavows claiming “a 
fundamental substantive due process right to treatment in an inpatient setting.”  Pl.’s Mem. 

in Opp’n at 27 n.7.  He alleges no facts addressing whether § 253B.10, subdiv. 1’s 48-hour 
rule, or a like concept, is “deeply rooted in this Nation’s history and tradition.”  Glucksberg, 
521 U.S. at 720–21.  A hypothetical failure to comply with the 48-hour rule might plausibly 
be  conscience-shocking  depending  on  the  failure’s  duration  and  perhaps  other 
considerations, but the Amended Complaint alleges no facts showing or implying that Mr. 

Dalen’s Stearns County detention was conscience-shocking in any respect specific to it.  
The Amended Complaint takes a different approach.  It appears to contend that every 
decision  to  detain  someone  who  is  civilly  committed  beyond  48  hours  is 
conscience-shocking, see Am. Compl. ¶¶ 64–65, but it contains no factual allegations that 
would plausibly support that categorical assertion.  Mr. Dalen cites no authority holding 

that a state official’s successful legislative advocacy might trigger a substantive-due-
process violation.                                                        
                          VII                                        
               The Preliminary Injunction Motion                     
Regarding Mr. Dalen’s motion for a preliminary injunction, the absence of merit to 

Mr. Dalen’s federal claims means he is not likely to prevail with respect to his § 1983 
damages claims or his claims challenging the 2023 amendment to § 253B.10, subdiv. 1.  
Mr.  Dalen  neither  distinguishes  his  state  constitutional  claims  from  his  federal 
constitutional  claims  nor  relies  on  his  state  tort  damages  claims  to  challenge 
implementation of the amendment.                                          
Nor has Mr. Dalen shown that he is likely to suffer irreparable harm.  As Mr. Dalen 

notes in his supporting brief, he has been admitted to a treatment facility.  See Pl.’s Mem. 
in Supp. [ECF No. 28] at 4.  Mr. Dalen identifies no particular ongoing threat that he will 
be charged with another crime and jailed while under a commitment order, and the 
likelihood of an unnamed potential class member being jailed while civilly committed 
cannot justify the issuance of an injunction in Mr. Dalen’s favor.        

The last two factors are the balance of the relative harms and the public interest.  For 
practical purposes, these factors “merge” when a plaintiff seeks injunctive relief against 
the government.  Nken v. Holder, 
556 U.S. 418, 435
 (2009); see Angelica C. v. Immigr. & 
Customs Enf’t, No. 20-cv-913 (NEB/ECW), 
2020 WL 3441461
, at *17 (D. Minn. June 5, 
2020), report and recommendation adopted, 
2020 WL 3429945
 (D. Minn. June 23, 2020).  

Now that he is receiving treatment, the harm Mr. Dalen might suffer in the absence of an 
injunction seems unclear and probably remote.  Public interest considerations do not clearly 
favor either party, but boil down to competing, sincerely held policy concerns that—absent 
a constitutional problem—the legislature is best positioned to assess.  See Let Them Play 
MN v. Walz, 
517 F. Supp. 3d 870
, 888 (D. Minn. 2021).                     

                          VIII                                       
               Where This Case Goes From Here                        
A district court “may decline to exercise supplemental jurisdiction over a claim . . . 
if . . . the district court has dismissed all claims over which it has original jurisdiction.”  
28 U.S.C. § 1367
(c)(3).  “[I]n the usual case in which all federal-law claims are eliminated 
before  trial,  the  balance  of  factors  to  be  considered  under  the  pendent  jurisdiction 
doctrine—judicial  economy,  convenience,  fairness,  and  comity—will  point  toward 

declining to exercise jurisdiction over the remaining state-law claims.”  Barstad v. Murray 
Cnty., 
420 F.3d 880, 888
 (8th Cir. 2005) (quoting Carnegie–Mellon Univ. v. Cohill, 
484 U.S. 343
, 350 n.7 (1988)).  And the Eighth Circuit has instructed district courts not to 
exercise supplemental jurisdiction over state-law claims when, as here, all federal claims 
are dismissed well before trial.  See Hervey v. Cnty. of Koochiching, 
527 F.3d 711
, 726–

27 (8th Cir. 2008).  Thus, without more, the dismissal of Mr. Dalen’s federal claims, 
combined with the absence of diversity jurisdiction under 
28 U.S.C. § 1332
(a), would 
prompt the with-prejudice dismissal of the federal claims, the entry of judgment on those 
claims, and remand of Mr. Dalen’s state claims to Dakota County District Court. 
Notwithstanding these principles, Mr. Dalen has asked that any dismissal be without 

prejudice.  Mr. Dalen represents that any dismissed claims might conceivably be repleaded 
with success.  This is because, as Mr. Dalen describes things, “new facts surrounding 
Defendant’s misconduct continue to become available, including Defendant failing to 
admit committed individuals even more than 48 hours after determining that a medically 
appropriate bed is available.”  Pl.’s Mem. in Opp’n at 42.  In view of Mr. Dalen’s request 

and these representations, the better answer is to allow Mr. Dalen the opportunity to file an 
amended  pleading  in  which  he  may  attempt  to  cure  the  dismissal-worthy  problems 
described in this order and perhaps allege additional facts discovered after briefing was 
closed on these motions.  Mr. Dalen’s federal constitutional claims will therefore be 
dismissed without prejudice, and Mr. Dalen will be given a deadline by which to file a 
Second Amended Complaint.  If he opts not file a Second Amended Complaint by the 
prescribed deadline, his federal constitutional claims will be dismissed with prejudice, 

judgment will be entered as to those claims, and the case will be remanded to Dakota 
County District Court.  Judgment will be entered at this time only with respect to the denial 
of Mr. Dalen’s motion for a preliminary injunction.                       

ORDER

Therefore, based upon the foregoing, and on all of the files, records, and proceedings 

herein, IT IS ORDERED THAT:                                               
1.   Defendant Jodi Harpstead’s Motion to Dismiss [ECF No. 11] is GRANTED 
IN PART.  Plaintiff Kyle Jerome Dalen’s claims arising under 
42 U.S.C. § 1983
 and/or 
the United States Constitution are DISMISSED WITHOUT PREJUDICE.           
2.   On or before February 6, 2024, Plaintiff Kyle Jerome Dalen may file a second 

amended complaint.  If no second amended complaint is filed by that deadline, judgment 
will be entered dismissing Mr. Dalen’s claims arising under 
42 U.S.C. § 1983
 and/or the 
United States Constitution with prejudice and the case will be remanded to Dakota County 
District Court for the reasons described in this Order.                   
3.   Plaintiff Kyle Jerome Dalen’s Motion for Preliminary Injunction [ECF No. 

26] is DENIED.                                                            
       LET JUDGMENT BE ENTERED ACCORDINGLY.                          

Date: January 16, 2024             s/ Eric C. Tostrud                     
                              Eric C. Tostrud                        
                              United States District Court           

Reference

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