HAYES v. SEVIER

CourtDistrict Court, S.D. Indiana
DecidedMay 19, 2025
Docket1:25-cv-00483
StatusUnknown

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

Bluebook
HAYES v. SEVIER, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

DUANE HAYES, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-00483-JMS-KMB ) MARK SEVIER, Warden; ) FOY, EMT; ) MILLIKEN, Dr.; ) JACOBS, Ms.; and ) JOHNSON, N.P., ) ) Defendants. ) Order Dismissing Complaint and Directing Filing of Amended Complaint

Plaintiff Duane Hayes is a prisoner at the New Castle Correctional Facility. He filed this lawsuit under 42 U.S.C. § 1983 alleging that Defendants violated his Eighth Amendment rights after causing him to fall and break his shoulder, and then failing to provide him proper medical treatment. [Filing No. 1-2.] Because Mr. Hayes is incarcerated, this Court must screen his Amended Complaint. 28 U.S.C. § 1915A(a), (c). I. SCREENING STANDARD When screening a complaint, the Court must dismiss any portion that is frivolous or malicious, fails to state a claim for relief, or seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915A(b). To determine whether the complaint states a claim, the Court applies the same standard as when addressing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). See Schillinger v. Kiley, 954 F.3d 990, 993 (7th Cir. 2020). Under that standard, a complaint must include "enough facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). "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 Court construes pro se complaints liberally and holds them to a "less stringent standard than formal pleadings drafted by lawyers." Cesal v. Moats, 851 F.3d 714, 720 (7th Cir.

2017). II. THE COMPLAINT Mr. Smith's factual allegations are accepted as true at the pleading stage. See Lisby v. Henderson, 74 F.4th 470, 472 (7th Cir. 2023). Mr. Hayes alleges that EMT Foy gave him medical booties that were too large for his feet, leading him to fall and injure his shoulder. [Filing No. 1- 2 at 5.] He states that Defendants Dr. Milliken, Ms. Jacobs, and Nurse Johnson knew of his injury and were supposed to help him get surgery but intentionally did not do so. [Filing No. 1-2 at 5.] Mr. Hayes filed suit in the Henry County Circuit Court against Warden Mark Sevier, EMT Foy, Dr. Milliken, Ms. Jacobs, and Nurse Johnson. [Filing No. 1-2 at 1.] In his Complaint, Mr. Hayes further alleged that Warden Sevier is responsible for not providing him with the proper healthcare. [Filing No. 1-2.] Mr. Hayes also asserts an Eighth Amendment claim of deliberate indifference to a serious medical need against all Defendants. [See Filing No. 1-2.] Mr. Hayes' Complaint requests access to medical care for his shoulder and damages from the Defendants. [Filing No. 1-2 at 4.] The Defendants have removed the action to this Court. [Filing No. 1.]

III. DISCUSSION OF CLAIMS Although a plaintiff need not plead legal theories in a complaint, see Fed. R. Civ. P. 8(a), Mr. Hayes has identified the theories he wishes to use—the Eighth Amendment against all Defendants. Where a pro se litigant has expressly stated the legal theory that he wishes to pursue, the district court is not required to analyze whether the allegations in the complaint might state a claim under a different legal theory. See Larry v. Goldsmith, 799 F. App'x 413, 416 (7th Cir. 2016) (citing Clancy v. Off. of Foreign Assets Control of U.S. Dep't of Treasury, 559 F.3d 595, 606-07 (7th Cir. 2009)). The Court analyzes Mr. Hayes claims only under the theories he has identified.

Applying the screening standard to the factual allegations in the Complaint, certain claims are dismissed while other claims shall proceed as submitted. A. Warden Sevier "A prisoner may not attribute any of his constitutional claims to higher officials by the doctrine of respondeat superior." Antonelli v. Sheahan, 81 F.3d 1422, 1428 (7th Cir. 1996). Therefore, a "supervising prison official" can be held liable under §1983 only if "that officer is shown to be personally responsible for a deprivation of a constitutional right." Vance v. Peters, 97 F.3d 987, 992 (7th Cir. 1996). To be held personally responsible, "the official must actually have participated in the constitutional wrongdoing." Antonelli, 81 F.3d at 1428 (citation omitted). In this case, Mr. Hayes has provided no allegation that the Warden had any direct involvement in his supposed injuries and failure to receive medical treatment. Thus, as a matter

of law, the Warden cannot be liable for Mr. Hayes's Eighth Amendment claim. The Eighth Amendment claim against Warden Sevier is DISMISSED. B. EMT Foy 1. Eighth Amendment The constitutional provision implicated by Mr. Hayes' claim is the Eighth Amendment's proscription against the imposition of cruel and unusual punishments. Helling v. McKinney, 509 U.S. 25, 31 (1993) ("It is undisputed that the treatment a prisoner receives in prison and the conditions under which he is confined are subject to scrutiny under the Eighth Amendment."). In order for an inmate to state a claim under § 1983 for medical mistreatment or the denial of medical care, the prisoner must allege "acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs." Estelle v. Gamble, 429 U.S. 97, 106 (1976). Deliberate indifference exists only when an official "knows of and disregards an excessive risk to an inmate's health; the official must both be aware of facts from which the inference could be drawn that a

substantial risk of serious harm exists, and he must also draw the inference." Farmer v. Brennan, 511 U.S. 825, 837 (1994) (construing Estelle). In this case, Mr. Hayes alleges that EMT Foy provided him with medical footwear several sizes too large, such that Mr. Hayes tripped and severely injured his shoulder. Under the above standard, Mr. Hayes may have, at most, stated a claim for negligence, but negligence alone does not state a claim of Eighth Amendment deliberate indifference against EMT Foy. Huber v. Anderson, 909 F.3d 201, 208 (7th Cir. 2018) (deliberate indifference "requires more than negligence). In any event, he states that EMT Foy was the cause of his injury, but that is merely a conclusion, and Mr.

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HAYES v. SEVIER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayes-v-sevier-insd-2025.