MARTIN v. VAUGHN

CourtDistrict Court, S.D. Indiana
DecidedOctober 22, 2020
Docket2:20-cv-00391
StatusUnknown

This text of MARTIN v. VAUGHN (MARTIN v. VAUGHN) 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
MARTIN v. VAUGHN, (S.D. Ind. 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

ROBERT MARTIN, ) ) Plaintiff, ) ) v. ) No. 2:20-cv-00391-JPH-MJD ) B. VAUGHN, ) RICHARD BROWN, ) ) Defendants. )

ENTRY SCREENING COMPLAINT, DISMISSING CLAIMS, AND DIRECTING SERVICE OF PROCESS

The plaintiff, Robert Martin, is currently an inmate at Wabash Valley Correctional Facility ("WVCF"). Because Mr. Martin is a "prisoner" as defined by 28 U.S.C. § 1915A(c), this Court has an obligation under 28 U.S.C. § 1915A(a) to screen his complaint. I. Screening Standard Pursuant to 28 U.S.C. § 1915A(b), the Court must dismiss the complaint if it is frivolous or malicious, fails to state a claim for relief, or seeks monetary relief against a defendant who is immune from such relief. In determining 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 Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017). To survive dismissal, [the] complaint must contain sufficient factual matter, accepted as true, to state a claim for relief that is plausible on its face. 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). Pro se complaints such as that filed by Mr. Martin are construed liberally and held to a less stringent standard than formal pleadings drafted by lawyers. Cesal, 851 F.3d at 720 (citing Perez v. Fenoglio, 792 F.3d 768, 776 (7th Cir. 2015)). II. The Complaint Mr. Martin names two defendants in his complaint: (1) Sgt. B. Vaughn and (2) WVCF Warden Richard Brown. Dkt. 1. At all times relevant to his complaint, Mr. Martin has been incarcerated at WVCF and has been diagnosed with type 1 diabetes, which requires him to use an

insulin pump. Id. at 4. Mr. Martin alleges that on August 14, 2019, he had a diabetic episode while in his housing cell that caused him to be in a stupor, incoherent, and unaware of his surroundings. Id. at 5. Mr. Martin's cellmate informed the staff of Martin's condition and medical was called but did not answer the phone. Id. The officers who responded to the request for help did not place an emergency medical alert, a signal 3000, which would have taken Mr. Martin to the infirmary. Id. Mr. Martin alleges that Sgt. Vaughn came to his cell, knew he was diabetic, and attempted to get him to go to the infirmary by talking to him for 45 minutes, but due to his condition, Mr. Martin could not understand what was happening. Id. at 6. Rather than calling a signal 3000, Sgt. Vaughn treated the situation "as a disciplinary matter and gave Martin an order to submit to having handcuffs placed on him" that Mr. Martin could not comply with due to his lack of understanding

the order. Id. at 6-7. Mr. Martin alleges that Sgt. Vaughn used excessive force by administering OC spray to his face that caused burning of his eyes, face, and lips. Id. at 7. Mr. Martin alleges he was saturated with the chemical agent and suffered chemical burns and irritation for a week after the incident. Id. Mr. Martin alleges that he was then taken to the infirmary by wheelchair where it was determined that he had suffered a very low blood sugar count. Id. Mr. Martin received a report of conduct from Sgt. Vaughn for refusal to comply with an order—which he alleges was a false conduct report that was issued to cover up the officer's wrongful actions. Id. at 8. The conduct report was later dismissed. Id. Further, Mr. Martin alleges that Warden Brown is responsible for training staff regarding the use of force and how to discern medical emergencies from disciplinary incidents. Id. at 2. He claims that Warden Brown has a "widespread custom, practice, and policy whereby he and staff at this facility seem to use illegal uses of force on a routine basis, because they are not properly

trained [or] properly supervised," or disciplined when excessive force is used. Id. at 8. Mr. Martin also brings a state law claim of emotional distress. He seeks declaratory relief and compensatory damages and brings his claims against the defendants in their individual and official capacities. Id. at 1, 13. III. Discussion of Claims Mr. Martin states his legal claims as: (1) Sgt. Vaughn used excessive force against him while he was experiencing a medical emergency in violation of the Fifth, Fourteenth, and Eighth Amendments; (2) Sgt. Vaughn wrote a false report of conduct against him in violation of the First, Fifth, Fourteenth, and Eighth Amendments; (3) Warden Brown maintains a custom, practice, or policy of allowing staff to use excessive force and failing to train and discipline staff, entitling

Martin to recover under Monell; and (4) a state law claim of emotional distress. Id. at 11-12. A. Dismissed Claims 1. Claims Against Warden Brown The Warden's federal liability is premised on Monell v. Dep't of Social Servs., 436 U.S. 658 (1978). A Monell claim is established by showing "'(1) an action pursuant to a municipal policy, (2) culpability, meaning that policymakers were deliberately indifferent to a known risk that the policy would lead to constitutional violations, and (3) causation, meaning the municipal action was the 'moving force' behind the constitutional injury." Pulera v. Sarzant, 966 F.3d 540, 550 (7th Cir. 2020) (quoting Hall v. City of Chi., 953 F.3d 945, 950 (7th Cir. 2020)). In this case, there is no municipal defendant. The Warden is a state actor. In addition, a Monell claim cannot be brought against an individual in his individual capacity. See Johnson v. Dykstra, No. 3-17-cv- 00071-PPS-MGG, 2019 WL 2270356, at *3 (N.D. Ind. May 24, 2019) ("A party may not assert a Monell claim against prison officers in their individual capacities. Recall that under section 1983,

only municipalities may be held liable for constitutional violations caused by their official policy including unwritten custom."). Similarly, even if the "failure to train claim" is not understood to be brought pursuant to the theory recognized in Monell, it is still subject to dismissal. This is because "failure to train claims are usually maintained against municipalities, not against individuals, and, in the Eighth Amendment context, such claims may only be maintained against a municipality." Brown v. Budz, 398 F.3d 904, 918 (7th Cir. 2005) (quoting Sanville v. McCaughtry, 266 F.3d 724, 739-40 (7th Cir. 2001)). Finally, any other constitutional claims brought against the Warden in his individual capacity must be dismissed. This is because there are no factual allegations that suggest that the

Warden was personally responsible for directing Sgt. Vaughn's actions on August 14, 2019.

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MARTIN v. VAUGHN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-vaughn-insd-2020.