Martratt v. Gladieux

CourtDistrict Court, N.D. Indiana
DecidedOctober 18, 2023
Docket1:23-cv-00117
StatusUnknown

This text of Martratt v. Gladieux (Martratt v. Gladieux) 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
Martratt v. Gladieux, (N.D. Ind. 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

ISAIAH MALIK BENJAMIN MARTRATT,

Plaintiff,

v. CAUSE NO. 1:23-CV-117-HAB-SLC

DAVID J. GLADIEUX,

Defendant.

OPINION AND ORDER Isaiah Malik Benjamin Martratt, a prisoner without a lawyer, filed a complaint against Allen County Sheriff David Gladieux seeking damages for being held in the unconstitutional conditions of confinement at the Allen County Jail identified in the class action Morris v. Sheriff of Allen County, No. 1:20-CV-34-DRL, 2022 WL 971098 (N.D. Ind. decided Mar. 31, 2022). ECF 1. “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). Nevertheless, under 28 U.S.C. § 1915A, the court must review the merits of a prisoner complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. Martratt alleges he was a pre-trial detainee while at the Allen County Jail, and therefore his rights arise under the Fourteenth Amendment. Miranda v. Cnty. of Lake, 900 F.3d 335, 352 (7th Cir. 2018) (citing Kingsley v. Hendrickson, 576 U.S. 389 (2015)). “[T]he Fourteenth Amendment’s Due Process Clause prohibits holding pretrial detainees in

conditions that ‘amount to punishment.’” Mulvania v. Sheriff of Rock Island Cnty., 850 F.3d 849, 856 (7th Cir. 2017) (citation omitted). To state a claim that a jail policy violates the Fourteenth Amendment, a plaintiff must allege that a resulting pretrial condition “is ‘imposed for the purpose of punishment,’ or . . . the condition ‘is not reasonably related to a legitimate goal—if it is arbitrary or purposeless . . ..’” Id. at 856 (quoting Bell v. Wolfish, 441 U.S. 520, 538-39 (1979). Courts consider whether “the challenged

governmental action is not rationally related to a legitimate governmental objective or [whether] it is excessive in relation to that purpose.” Id. (quoting Kingsley, 576 U.S. at 398). In Morris, the court found at summary judgment that certain conditions of confinement at the Allen County Jail violated the Eighth and Fourteenth Amendments

to the Constitution: “The overcrowding problem at the jail—which in turn has spawned an increased risk of violence, unsanitary and dangerous conditions in cells, insufficient recreation, and classification difficulties—has deprived this class of inmates ‘the minimal civilized measure of life’s necessities.’” 2022 WL 971098 at *5 (quoting Farmer v. Brennan, 511 U.S. 825, 834 (1994)). The court entered a permanent injunction to

address the overcrowding, lack of sufficient staffing and recreation, and inadequate supervision of prisoners, and it continues to monitor the remediation of the unconstitutional conditions. Id. at *17. But in this suit for damages, simply being in the presence of unconstitutional conditions of confinement is not enough to state a claim unless a plaintiff can show he was injured by the conditions.

Overcrowding, on its own, does not state a constitutional claim, and instead the court must look to the effects the overcrowding has on the conditions of confinement. See Bell v. Wolfish, 441 U.S. 520, 541 (1979) (“While confining a given number of people in a given amount of space in such a manner as to cause them to endure genuine privations and hardship over an extended period of time might raise serious questions under the Due Process Clause as to whether those conditions amounted to punishment,

nothing even approaching such hardship is shown by this record.”); see also Hubbard v. Taylor, 538 F.3d 229 (3d Cir. 2008) (after determining that the triple-celling of pretrial detainees was rationally related to managing an overcrowded facility, the court turned to “whether these conditions cause inmates to endure such genuine privations and hardship over an extended period of time, that the adverse conditions become excessive

in relation to the purposes assigned to them” (quotation marks omitted)). For example, overcrowding could lead to deprivations of essential food, medical care, or sanitation, cause an increase in violence, or result in other intolerable prison conditions. Rhodes v. Chapman, 452 U.S. 337, 348 (1981). Martratt’s complaint plausibly alleges that as a result of the overcrowding, he

was subjected to unconstitutional conditions of confinement that injured him. Martratt alleges that during his confinement from October 4, 2020, through July 2021, he had no rec time. C-Block, where he was housed, was a very small block and had excessive overcrowding. Without an opportunity for recreation, he alleges that he was not able to move around sufficiently during his nine months at the jail. As a result, he says he lost a lot of muscle mass and developed pain and body aches in his spine, lower back, hips,

leg, neck, and other joints. He also experienced mental fatigue and frustration. Martratt plausibly alleges that spending nine months in overcrowded conditions, coupled with the lack of recreation, could amount to punishment. Cf. James v. Pfister, 708 F. App’x 876, 879 (7th Cir. 2017) (“Our decisions are clear that preventing inmates from exercising for prolonged periods may violate the Eighth Amendment.”); Gray v. Hardy, 826 F.3d 1000, 1005 (7th Cir. 2016) (“An adverse condition of confinement, if endured over a significant

time, can become an Eighth Amendment violation even if it would not be impermissible if it were only a short-term problem.”). Martratt also alleges that the overcrowding and understaffing caused problems on an occasion when his dorm became filled with smoke to the point where it was hard to see and extremely hard to breathe. He and the other occupants on his dorm were not

let out of the dorm for an hour, and in the rush of inmates exiting the dorm, he was pushed down the stairs. He says that he could not walk without limping for two weeks and continues to have back problems and trouble breathing. Martratt has plausibly alleged that the overcrowded and understaffed conditions led to a delay in the evacuation and contributed to more disorderly evacuation, causing him injury.

Martratt also alleges that he fell victim to two physical assaults while he was detained at the jail. In one, he says his food tray was taken from him and he was not able to eat until the next meal. The other alleged assault is undescribed. He alleges these assaults were not witnessed by staff. The lack of detail about the circumstances of the assaults does not allow a reasonable inference that the alleged attacks were connected to the overcrowding, and he alleges no details suggesting the sheriff was personally

involved in the assault or in failing to prevent it. See Kemp v.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
McMillian v. Monroe County
520 U.S. 781 (Supreme Court, 1997)
Cutter v. Wilkinson
544 U.S. 709 (Supreme Court, 2005)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
James J. Kaufman v. Gary R. McCaughtry
419 F.3d 678 (Seventh Circuit, 2005)
Richard Budd v. Edward Motley
711 F.3d 840 (Seventh Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Hubbard v. Taylor
538 F.3d 229 (Third Circuit, 2008)
James J. Kaufman v. Jeffrey Pugh
733 F.3d 692 (Seventh Circuit, 2013)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Marcos Gray v. Marcus Hardy
826 F.3d 1000 (Seventh Circuit, 2016)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Kirk Horshaw v. Mark Casper
910 F.3d 1027 (Seventh Circuit, 2018)
First Midwest Bank v. City of Chicago
988 F.3d 978 (Seventh Circuit, 2021)
Gregory Kemp v. Fulton County, Illinois
27 F.4th 491 (Seventh Circuit, 2022)
Mulvania v. Sheriff of Rock Island County
850 F.3d 849 (Seventh Circuit, 2017)
James v. Pfister
708 F. App'x 876 (Seventh Circuit, 2017)

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Martratt v. Gladieux, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martratt-v-gladieux-innd-2023.