Crafton v. Davis

CourtDistrict Court, N.D. Indiana
DecidedSeptember 22, 2025
Docket1:24-cv-00155
StatusUnknown

This text of Crafton v. Davis (Crafton v. Davis) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crafton v. Davis, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

DEMETRIUS CRAFTON,

Plaintiff,

v. CAUSE NO. 1:24-CV-155-JD-JEM

WENDY DAVIS, BAILEY GOODWIN, TIMOTHY STUCKY, ALLEN, THE COUNTY OF, ALLEN COUNTY COMMUNITY CORRECTIONS RESIDENTIAL SERVICES, ALLEN COUNTY COMMUNITY CORRECTIONS, STANLEY CAMPBELL, EDWARD STITES, CODY FRY, MALLORY KUTER, KYLE KEUNEKE, TED GALLMEYER, KIMBERLY CHURCHWARD, BINIAK, THOMPSON, ALLEN, TROY HERSHBERGER,

Defendants.

OPINION AND ORDER Demetrius Crafton was a prisoner when he filed this case, but he has since been released.1 He continues to represent himself and has filed an amended complaint after the court determined that his initial complaint did not state a claim for relief. ECF 11, 20. Under 28 U.S.C. § 1915A, the court must review the merits of that amended complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon

1 Following his release from custody, Crafton was instructed that he needed to resolve his filing fee status by either paying the remainder he owed on the filing fee or by filing a motion to proceed in forma pauperis. He paid the filing fee in full. ECF 28. Therefore, his motions for leave to proceed in forma pauperis will be denied as moot. ECF 24, ECF 26. which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. “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). Crafton’s complaint concerns the period of time in which he was participating in a deferred prosecution in Allen County. His amended complaint repeats allegations about being jail without due process and the performance of his public defenders, but it

adds more detail about what happened, includes new claims about the conditions of confinement at the residential facility where he was placed and about alleged retaliation by facility staff, and names nine additional defendants. Notably, Crafton includes transcripts from the hearings before the State court, which provide even more context for his claims.2 The amended complaint raises four general issues: (1) allegations that

Crafton was deprived of liberty without due process; (2) conditions of confinement at the county residential facility where he was placed for part of the time; (3) retaliation for filing grievances; and (4) issues with the underlying plea agreement.

2 The Federal Rules of Civil Procedure provide that “[a] copy of a written instrument that is an exhibit to a pleading is a part of the pleading for all purposes.” FED. R. CIV. P. 10(c). When the plaintiff references and relies on it, “the contents of that document become part of the complaint and may be considered as such when the court [determines] the sufficiency of the complaint.” Williamson v. Curran, 714 F.3d 432, 436 (7th Cir. 2013) (citations omitted). Therefore, the court will rely on the contents of the exhibits in this order. (1) Due Process Crafton was charged with Operating a Vehicle while Intoxicated in two cases. See State v. Crafton, No. 02C01-2207-F6-000802 (Allen Super. Ct. filed July 14, 2022); State v.

Crafton, No. 02C01-2012-F6-001534 (Allen Super. Ct. filed Dec. 14, 2020), available at mycase.in.gov. He agreed to participate in a deferral program. See IND. CODE § 33-23-16- 14(a) (allowing a court to “defer proceedings against an individual and place the individual in a problem solving court program” if certain conditions are met). As part of that program, Crafton pleaded guilty in the two cases before Allen County Judge

Wendy Davis, and she took the plea agreements under advisement while Crafton participated in the deferral program. If Crafton successfully completed the requirements of the deferral program, the prosecutions would be dismissed and he would have no convictions for these cases on his record. Id. § 33-23-16-14(c). If, however, he was unsuccessful, the prosecution could be resumed and a criminal

conviction entered. Id. at § 33-23-16-14(b). The deferral was ultimately unsuccessful, and Crafton was sentenced to the Indiana Department of Correction (“IDOC”). Before Crafton was sentenced to IDOC, he spent just over a year in the deferral program. He began the deferral period living in a residential facility through the Allen County Community Corrections Residential Services (“ACCCRS”). During that year,

Judge Davis remanded him to the Allen County Jail on a few occasions in proceedings that Crafton alleges did not comply with due process. Federal due process protections under the Fourteenth Amendment require, at a minimum, that he receive notice and an opportunity to be heard before he can be sanctioned with jail time.3 See Simpson v. Brown Cnty., 860 F.3d 1001, 1006 (7th Cir. 2017) (“The basic rights guaranteed by

constitutional due process are notice of the intended adverse government action and an opportunity to be heard in response, although more elaborate procedural rights—such as the rights to present evidence, to confront adverse witnesses, and to be represented by counsel—may apply in cases in which vital private interests are at risk.”). Indiana law gives Crafton more procedural rights than those.4 If an individual is alleged to have violated a condition of the deferral program, Indiana law specifies the procedures to be

followed: (1) The state must prove the violation by a preponderance of the evidence. (2) The evidence must be presented in open court. (3) The individual who is alleged to have committed the violation is entitled to: (A) receive written notice of the alleged violation; (B) obtain the disclosure of evidence against the individual; (C) confront and cross-examine witnesses; and (D) be represented by counsel.

IND. CODE § 33-23-16-14.5(c). Crafton attached transcripts of the hearings to his amended complaint suggesting these procedural protections were not always followed before Crafton was sent to jail. As part of the deferral program, Crafton had weekly meetings with Judge Davis and members of the supervision team. At a meeting on November 9, 2022, Judge

3 The court notes a distinction between a jail stay as a sanction for a violation and being placed in jail pending a hearing on that violation. Indiana law regarding deferred prosecutions specifies that a problem solving court may remand the individual into custody “[i]f it is alleged that an individual has violated at least one (1) condition of a problem solving court program.” IND. CODE § 33-23-16-14.5(b)(1). Beng placed in jail pending a hearing on a violation would not require all those procedures to be observed, though other constitutional limits would apply. 4 It is unnecessary to decide here whether the federal due process protections are co-extensive with the procedural protections provided by Indiana law. Davis was made aware of an argument between Crafton and a staff member at ACCCRS. She asked Crafton why he was “being rude to my staff.” ECF 20-1 at 31. The

following exchange occurred: DEFENDANT: I don’t know what you, I, I’m not sure what you are talking about.

THE COURT: You’re out at CCRS right now, correct?

DEFENDANT: Yes.

THE COURT: I’m going to remand you into custody.

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