Logan Kramer v. Christopher Schmaling

CourtDistrict Court, E.D. Wisconsin
DecidedOctober 28, 2025
Docket2:25-cv-00448
StatusUnknown

This text of Logan Kramer v. Christopher Schmaling (Logan Kramer v. Christopher Schmaling) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Logan Kramer v. Christopher Schmaling, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ______________________________________________________________________________ LOGAN KRAMER,

Plaintiff, v. Case No. 25-cv-448-pp

CHRISTOPHER SCHMALING,

Defendant. ______________________________________________________________________________

ORDER ADOPTING IN PART, MODIFYING IN PART AND REJECTING IN PART JUDGE DUFFIN’S REPORT AND RECOMMENDATION (DKT. NO. 14), ALLOWING PLAINTIFF TO FILE AMENDED COMPLAINT AND RESERVING RULING ON PLAINTIFF’S MOTION TO APPOINT COUNSEL (DKT. NO. 4) ______________________________________________________________________________

Plaintiff Logan Kramer filed this lawsuit alleging violations of his civil rights. Dkt. No. 1. On September 29, 2025, Magistrate Judge William Duffin issued a report recommending that this district court dismiss the case for failure to state a claim and that the court enter judgment, impose a strike and deny as moot the plaintiff’s motion to appoint counsel. Dkt. No. 14. The court has not received from the plaintiff an objection to the order, and the deadline for him to file such an objection has passed. The copy of Judge Duffin’s order sent to the plaintiff at the Sheridan Correctional Center in Sheridan, Illinois, was returned to the court as undeliverable. Dkt. No. 15. The envelope states that “No one with this name/number” is confined at Sheridan. Id. The Illinois Department of Corrections’ Individual in Custody Search shows that the plaintiff was released onto parole on August 13, 2025. See https:// idoc.illinois.gov/offender/inmatesearch.html (DOC #Y40376). The clerk’s office advised the plaintiff early in the case to “immediately notify the court” if his address changed while the case was pending. Dkt. No. 5. Judge Duffin also told the plaintiff in the April 9, 2025 order assessing an initial partial filing fee that he must notify the clerk if his address changed and that failure to do so meant that the court could dismiss his case for failure to prosecute. Dkt. No. 9 at 4. Despite these warnings, the plaintiff did not notify the court when he was released from custody and has not provided an updated address where the court can reach him. The plaintiff’s failure to comply with the court’s instructions and orders is grounds for dismissal of this case without prejudice. See Civil Local Rule 41(c) (E.D. Wis.) Rather than dismiss the case, the court will adopt Judge Duffin’s recommendation in part, modify the recommendation in part and reject the recommendation in part. The court will dismiss the complaint for failure to state a claim but will give the plaintiff an opportunity to file an amended complaint. The court will not impose a strike and will reserve ruling on the plaintiff’s motion to appoint counsel pending receipt of his amended complaint. I. Background A. The Complaint (Dkt. No. 1) The court received the plaintiff’s complaint on March 25, 2025. Dkt. No. 1. The complaint alleges that on April 21, 2021, deputies from the Racine County Sheriff’s Office arrested the plaintiff and seized an urn that contained the ashes of his relative. Id. at ¶¶1–2. The plaintiff says that the charges against him were dismissed more than three years later, on August 12, 2024. Id. at ¶3. The plaintiff then contacted the Sheriff’s Office to retrieve the urn, but the office told him that they did not have it. Id. at ¶¶4–5. He asserts that this constituted an illegal seizure of his property and/or a deprivation of his property without due process of law. ¶6. He seeks $10,000 in damages and the return of the urn and ashes or, if the remains have been lost or destroyed, $1 million in damages. Id. at p.4. B. Judge Duffin’s Screening Order and Recommendation (Dkt. No. 13) Judge Duffin screened the complaint and concluded that the complaint did not state a claim for relief. Dkt. No. 13. Judge Duffin first explained that although the Fourteenth Amendment “prohibits a state from depriving ‘any person of life, liberty, or property, without due process of law,’” no federal remedy is available when “a plaintiff has remedies under Wisconsin state law to address the deprivation of property.” Id. at 4 (citing Edmonson v. Marcell, Case No. 22-CV-671-JPS, 2023 WL 5608832 at *3 (E.D. Wis. Aug. 30, 2023)). Judge Duffin determined that because nothing in the complaint “suggests that the state remedies would be inadequate,” the complaint “fail[ed] to state a claim upon which relief may be granted.” Id. He recommended that this court dismiss the case, enter judgment, impose a strike because the complaint failed to state a claim, see 28 U.S.C. §1915(g), and deny as moot the plaintiff’s motion to appoint counsel (Dkt. No. 4). Dkt. No. 14 at 4–5. II. Legal Standard A district judge may “accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate.” 28 U.S.C. §636(b)(1); Federal Rule of Civil Procedure 72(b)(3). When a party does not object to the recommendation, the district judge may reconsider the magistrate judge’s ruling “where it has been shown that the magistrate judge’s order is clearly erroneous or contrary to law.” 28 U.S.C. §636(b)(1)(A). III. Discussion The court agrees with Judge Duffin that the complaint does not state a claim under the Fourteenth Amendment. As Judge Duffin explained, claims for deprivation of property are not actionable under §1983 if adequate state remedies are available to redress the deprivation, even if the property is taken intentionally. See Morris v. Scott, 840 F. App’x 14, 15 (7th Cir. 2021) (citing Hudson v. Palmer, 468 U.S. 517, 533 (1984); and Wynn v. Southward, 251 F.3d 588, 592–93 (7th Cir. 2001)) (“Unauthorized deprivations of property violate the due-process clause only when no post-deprivation procedures are available.”). Wisconsin law provides adequate “tort remedies for property that is converted, damaged or destroyed by another.” Neumann v. City of Franklin Police Dep’t, Case No. 24-cv-818-pp, 2024 WL 4678965, at *2 (E.D. Wis. Nov. 5, 2024) (citing Vollmer v. Green Bay City Police Dep’t, Case No. 18-cv-1629, 2018 WL 6067240, at *3 (E.D. Wis. Nov. 20, 2018); Wis. Stat. §§893.35, 893.51 and 893.52). That means that the plaintiff cannot state a Fourteenth Amendment claim regarding his lost or taken urn. But Judge Duffin did not address the plaintiff’s alternate claim that the sheriff’s deputies took his urn in violation of his rights under the Fourth Amendment. The Fourth Amendment protects against unreasonable seizures of property, including personal property, by government actors. See Bell v. City of Chicago, 835 F.3d 736, 739 (7th Cir. 2016). Generally, “‘seizures of personal property are unreasonable within the meaning of the Fourth Amendment . . . [unless] accomplished pursuant to a judicial warrant.’” United States v. Burgard, 675 F.3d 1029, 1032 (7th Cir. 2012) (quoting Illinois v. McArthur, 531 U.S. 326, 330 (2001) (cleaned up)). The Court of Appeals for the Seventh Circuit has held that a plaintiff has a valid claim in federal court when he “seeks return of property based on lack of probable cause to confiscate the property.” Gullikson v.

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Related

Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Illinois v. McArthur
531 U.S. 326 (Supreme Court, 2001)
United States v. Burgard
675 F.3d 1029 (Seventh Circuit, 2012)
Sylvester E. Wynn v. Donna Southward
251 F.3d 588 (Seventh Circuit, 2001)
Bell v. City of Chicago
835 F.3d 736 (Seventh Circuit, 2016)

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Bluebook (online)
Logan Kramer v. Christopher Schmaling, Counsel Stack Legal Research, https://law.counselstack.com/opinion/logan-kramer-v-christopher-schmaling-wied-2025.