Aron-El v. Neal

District Court, N.D. Indiana·Decided May 12, 2025·No. 3:24-cv-00532·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

TITUS ARON-EL,

Plaintiff,

v. CAUSE NO. 3:24-CV-532-GSL-JEM

RON NEAL, et al.,

Defendants.

OPINION AND ORDER Titus Aron-El, a prisoner without a lawyer, filed an amended complaint. ECF 16. “A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted). Nevertheless, under 28 U.S.C. § 1915A, the court must review the merits of a prisoner complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. Aron-El alleges that he has been housed in Indiana State Prison’s “C” cell house since January 2024. When he arrived, he was placed in a cell that had not been cleaned. There was human waste, which he had to clean up without the benefit of adequate supplies. Additionally, the door to Aron-El’s cell was damaged and hanging off the hinges. He further alleges that pigeons and other birds have taken up residence in the cell house, and he has developed breathing and eye problems due to exposure to their excrement coupled with an inadequate ventilation system. He also alleges that the medical treatment he received for his breathing and eye problems was inadequate. He

is suing Indiana Department of Correction, Warden Ron Neal, and Debra Taylor, the Hazardous Materials Supervisor and Pest-Control Inspector, for subjecting him to unconstitutional conditions of confinement, and providing inadequate medical care. His amended complaint seeks both monetary damages and injunctive relief.

Aron-El’s Conditions of Confinement Claims

The Eighth Amendment prohibits conditions of confinement that deny inmates “the minimal civilized measure of life’s necessities.” Townsend v. Fuchs, 522 F.3d 765, 773 (7th Cir. 2008). In evaluating an Eighth Amendment claim, courts conduct both an objective and a subjective inquiry. Farmer v. Brennan, 511 U.S. 825, 834 (1994). The objective prong asks whether the alleged deprivation is “sufficiently serious” that the

action or inaction of a prison official leads to “the denial of the minimal civilized measure of life’s necessities.” Id. Although “the Constitution does not mandate comfortable prisons,” Rhodes v. Chapman, 452 U.S. 337, 349 (1981), inmates are entitled to adequate food, clothing, shelter, bedding, hygiene materials, and sanitation. Knight v. Wiseman, 590 F.3d 458, 463 (7th Cir. 2009); Gillis v. Litscher, 468 F.3d 488, 493 (7th Cir.

2006). Prolonged exposure to infestations can be serious enough to amount to an Eighth Amendment violation. See Davis v. Williams, 216 F.Supp.3d 900, 907-08 (N.D.Ill. 2016). On the subjective prong, the prisoner must show the defendant acted with deliberate indifference to the inmate’s health or safety. Farmer, 511 U.S. at 834. As the

Seventh Circuit has explained: [C]onduct is deliberately indifferent when the official has acted in an intentional or criminally reckless manner, i.e., the defendant must have known that the plaintiff was at serious risk of being harmed and decided not to do anything to prevent that harm from occurring even though he could have easily done so.

Board v. Farnham, 394 F.3d 469, 478 (7th Cir. 2005) (internal citations and quotation marks omitted); see also Reed v. McBride, 178 F.3d 849, 855 (7th Cir. 1999) (where inmate complained about severe deprivations but was ignored, he established a “prototypical case of deliberate indifference”). Aron-El asserts that pigeons and other birds are living in the cell house and their excrement is everywhere. He further asserts that the ventilation system does not use any kind of filtering system so dried excrement is recirculated. Aron-El’s earlier complaint indicated that he suffered from respiratory health problems that he associated with the conditions in the cell, but it did not indicate what symptoms he experienced, when he started experiencing them, why he believes the symptoms are linked to the presence of pigeons, when he sought medical care, or what medical care, if any, was provided. In the amended complaint, Aron-El clarifies that he began having shortness of breath, dizziness, and eye problems after living in the unit. He filed out several health care request forms between March 10, 2024, and May 10, 2024. In one of those requests, he says he did not have problems with breathing or his eyes before being housed in “C” cell house and he believes the problems are due to the bird excrement. ECF 16-1 at 10. He indicates that his requests for medical care were not

responded to until May 22, 2024. He does not say if he saw a health care provider and he does not provide any other details about the response, but the exhibits attached to his amended complaint show that he was prescribed allergy medication. ECF 16-1 at 13. Giving Aron-El the benefit of all plausible inferences, these allegations are sufficient to satisfy the objective component of the analysis. On the subjective prong of the analysis, Aron-El asserts that he addressed his

concerns in a grievance dated May 9, 2024. He never received a response to the grievance. Outside of filing a grievance in May 2024, he describes no further interactions with either Warden Ron Neal or Debra Taylor, although he claims they were both aware of the conditions due to unspecified complaints by other inmates. “[P]ublic employees are responsible for their own misdeeds but not for anyone

else’s.” Burks v. Raemisch, 555 F.3d 592, 596 (7th Cir. 2009). Supervisors can also be held liable if they “know about the conduct and facilitate it, approve it, condone it, or turn a blind eye for fear of what they might see.” Matthews v. City of East St. Louis, 675 F.3d 703, 708 (7th Cir. 2012). Given the nature of her position, it is plausible to infer that ISP’s pest inspector, Debra Taylor, was aware of the conditions related to bird excrement that

Aron-El describes in “C” cell house and failed to take action to remedy those conditions, so Aron-El will be permitted to proceed against her on an Eighth Amendment claim for subjecting him to unconstitutional conditions of confinement caused by pigeon excrement. However, it is not plausible to infer that Debra Taylor had any knowledge or our control over the condition of Aron-El’s cell upon his arrival. And, it is not plausible to infer that Warden Neal was aware of the conditions of Aron-El’s

cell or dorm such that he could be held individually liable. However, Aron-El will be granted leave to proceed against Warden Neal in his official capacity for permanent injunctive relief from the conditions created by long-term exposure to bird excrement. See Gonzalez v.

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