James, Carlos v. Butzke, Heather

CourtDistrict Court, W.D. Wisconsin
DecidedMarch 18, 2024
Docket3:21-cv-00575
StatusUnknown

This text of James, Carlos v. Butzke, Heather (James, Carlos v. Butzke, Heather) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James, Carlos v. Butzke, Heather, (W.D. Wis. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

CARLOS JAMES,

Plaintiff, OPINION and ORDER v.

21-cv-575-wmc HEATHER BUTZKE,

Defendant.

Prisoner Carlos James claims that defendant Heather Butzke, a correctional officer at Kettle Moraine Correctional Institution (“KMCI”) accused him of being a “snitch,” thus exposing him to threats and harassment by other inmates in violation of his rights under the Eighth Amendment and Wisconsin negligence law. Before the court is defendant’s motion for summary judgment. The court will grant the motion on James’ Eighth Amendment claim because, even viewing the evidence in a light most favorable to James, no reasonable jury could find that defendant violated his constitutional rights. In the absence of a viable federal claim the court will also decline to exercise supplemental jurisdiction over James’ negligence claim, which will be dismissed without prejudice. UNDISPUTED FACTS1 On June 12, 2021, James was serving a three-day, 24-hour room confinement at KMCI following disposition of a previous conduct report. The conditions of his confinement included that he was not permitted to obtain or possess hot water, either personally or through another

1 Except where noted, the following facts are drawn in the light most favorable to plaintiff, as the nonmoving party, from defendant’s proposed findings of facts and plaintiff’s responses. inmate. However, during his confinement, Correctional Officer Butzke observed James exit the bathroom with a cup of coffee, prompting her to ask what he was doing in the bathroom with the cup of coffee, to which he replied, “hot water.” Since this meant James had acted in direct violation of his 24-hour room confinement, as well as a direct violation of the bathroom

rules prohibiting inmates from bringing cups, bowls, or food into the bathroom, Officer Butzke asked James Butzke issued James a conduct report for disobeying orders. As per KMCI’s policy, Butzke also notified a sergeant of her issuance of a conduct report, and the sergeant called James to the officer’s station. James stated that “the ticket was not truthful” because he did not actually get hot water from the bathroom. Rather, James explained he already had the coffee made when he entered the bathroom. The sergeant and Butzke then reviewed the security footage showing that: James actually brought a cup from his cell, handed it to another inmate, who then heated up the coffee in the unit’s microwave,

and left it in the bathroom for James to pick up. After reviewing this footage, Butzke next called the other inmate to the officer’s station and told him that she knew he had heated up coffee for James, which violated policy because he was then on 24-hour room confinement. Further, according to James, Butzke told the inmate that it was James who had “thrown him under the bus.” Butzke denies saying this, but agrees she gave the other inmate a warning about the restrictions of room confinement. The other inmate then left the officer’s station and allegedly informed several inmates that James had “snitched” on him. When Officer Butzke delivered a

copy of James’s conduct report to his cell, she also allegedly loudly announced, “Thanks for telling me, now you got someone else in trouble,” although again Butzke denies saying this. After the incident, other inmates accused James of being a snitch and subjected him to insults and verbal abuse. More specifically, although he was not seriously harmed physically by any other inmate because of the snitch rumor, James claims that he was repeatedly mocked and harassed by other inmates, and once in August 2021, an inmate who was teasing him also

intentionally, “physically bumped” into him. In addition, James claims to have suffered anxiety attacks because of the comments from other inmates, for which he sought both psychological services and a transfer to a different institution.

OPINION The Eighth Amendment of the U.S. Constitution mandates that prison officials “take reasonable measures to guarantee the safety of the inmates themselves,” Hudson v. Palmer, 468 U.S. 517, 526–27 (1984), which includes a duty to protect prisoners from violence at the hands of other prisoners. Farmer v. Brennan, 511 U.S. 825, 833 (1994); Moore v. W. Illinois Corr. Ctr.,

89 F.4th 582, 590–91 (7th Cir. 2023). “Prison officials who recklessly expose a prisoner to a substantial risk of a serious physical injury violate his Eighth Amendment rights.” Smith v. Peters, 631 F.3d 418, 421 (7th Cir. 2011). Plaintiff claims that defendant’s comments to an inmate that plaintiff “threw him under the bus,” as well as her comments within earshot of yet other inmates that plaintiff “got someone else in trouble” -- deliberately exposed him to a substantial risk of serious harm in violation of his constitutional rights. To overcome defendant’s motion for summary judgment on this Eighth Amendment claim, plaintiff must provide evidence from which a reasonable jury

could conclude defendant both knew of and deliberately disregarded a substantial risk of serious harm to plaintiff’s health or safety. See Gevas v. McLaughlin, 798 F.3d 475, 480 (7th Cir. 2015). Said another way, plaintiff must show: (1) defendant was aware of facts from which an inference could be drawn that a substantial risk of serious harm existed; and (2) she must also have drawn that inference. Farmer, 511 U.S. at 837. As a threshold matter, defendant argues that plaintiff’s experience of non-physical

jeering, harassing statements and a shoving incident do not qualify as “serious harm” sufficient to sustain a constitutional claim. See Lord v. Beahm, 952 F.3d 902, 905 (7th Cir. 2020) (holding that “trivial” injuries consisting of “minor scratches” were insufficient to sustain Eighth Amendment claim). Plaintiff responds that the psychological injuries he suffered, including anxiety and difficulty sleeping, are sufficient to maintain his constitutional claim. The court need not resolve this dispute, however, because plaintiff’s Eighth Amendment claim fails on the subjective element of his claim: he cannot show that defendant acted with deliberate indifference to a substantial risk of serious harm.

Plaintiff argues that defendant knew, or should have known, that outing him as a “snitch” to other inmates on his unit would place him at a substantial risk of serious harm, citing several cases in support. But all are distinguishable, as each involved substantially more serious risks than present in this case. For example, plaintiff cites Leary v. Livingston Cnty., 528 F.3d 438, 442 (6th Cir. 2008), a case in which a correctional officer told other inmates that the plaintiff had been charged with raping a nine-year old girl, while at the same time acknowledging the serious risk of harm that the plaintiff faced once other inmates learned of the charges. Id. at 442 (officer told plaintiff “to keep his mouth shut about his charges ... [f]or

his own safety” because he “fear[ed that someone might] assault[ ] him [for] a charge like that.”) Thus, in Leavy, the officer’s own words allowed a jury to find that he was subjectively “aware of facts from which the inference could be drawn that a substantial risk of serious harm exist[ed]” and that he “dr[ew] the inference.” Farmer, 511 U.S. at 837.

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Related

Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Smith v. Peters
631 F.3d 418 (Seventh Circuit, 2011)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Leary v. Livingston County
528 F.3d 438 (Sixth Circuit, 2008)
Grieveson v. Anderson
538 F.3d 763 (Seventh Circuit, 2008)
David Gevas v. Christopher McLaughlin
798 F.3d 475 (Seventh Circuit, 2015)
Christopher Coleman v. City of Peoria, Illinois
925 F.3d 336 (Seventh Circuit, 2019)

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James, Carlos v. Butzke, Heather, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-carlos-v-butzke-heather-wiwd-2024.