Larry Schultz v. Nancy Johnston, a231541

Appellant Larry Schultz was civilly committed to the Minnesota Sex Offender Program (MSOP) in Moose Lake, MN.
While temporarily at the Forensic Nursing Home (FNH) in St. Peter, he purchased a refurbished video-game console, which was permissible there.
Upon return to MSOP, his console was confiscated as contraband per MSOP policy prohibiting refurbished electronics.
Schultz filed internal requests for the return of his console, which were denied according to policy.
Schultz, proceeding pro se, filed a complaint alleging constitutional violations under 42 U.S.C. § 1983 against MSOP employees; the district court dismissed the complaint for failure to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourth Amendment Seizure	Seizure of console violated his right to privacy.	Policy justified by need for security.	Dismissed: Failed to state unreasonable seizure.
Substantive Due Process	Policy arbitrarily infringes on his rights.	Policy serves legitimate government purpose.	Dismissed: Policy is not egregious or punitive.
Procedural Due Process	No sufficient process for deprivation of property.	No constitutional right to such property.	Dismissed: No protected property interest implicated.
Return of Property (Statute)	Entitled to return under Minn. Stat. § 626.21.	Seizure was not unlawful under policy.	Dismissed: No illegal seizure shown.

In re Welfare of B.R.K., 658 N.W.2d 565 (Minn. 2003) (expectation of privacy analysis under Fourth Amendment for committed persons)
Carrillo v. Fabian, 701 N.W.2d 763 (Minn. 2005) (scope of Fourteenth Amendment protection for committed individuals)
Mumm v. Morrison, 708 N.W.2d 475 (Minn. 2006) (standard for substantive due process claims)
Graphic Commc'ns Loc. 1B Health & Welfare Fund "A" v. CVS Caremark Corp., 850 N.W.2d 682 (Minn. 2014) (standard for Rule 12.02(e) motion to dismiss)
Hall v. State, 908 N.W.2d 345 (Minn. 2018) (elements of procedural due process claims)