McCracken v. Kirby

CourtDistrict Court, N.D. Indiana
DecidedAugust 20, 2025
Docket3:23-cv-00908
StatusUnknown

This text of McCracken v. Kirby (McCracken v. Kirby) 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
McCracken v. Kirby, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

RICHARD MCCRACKEN,

Plaintiff,

v. CAUSE NO. 3:23-CV-908-PPS-AZ

KIRBY and HENSLEY,

Defendants.

OPINION AND ORDER Richard McCracken, a prisoner without a lawyer, is proceeding in this case on two claims: (1) against Sergeant Megan Hensley “in her personal capacity for monetary damages under the Eighth Amendment for failing to intervene in the use of excessive force by Officer John Doe;” and (2) against Sgt. Hensley and Sergeant Kameo Kirby “in their personal capacity for monetary damages for denying him the minimal civilized measure of life’s necessities in violation of the Eighth Amendment[.]” ECF 14 at 8. On October 21, 2024, the defendants filed a motion for summary judgment. ECF 75. With the motion, the defendants provided McCracken the notice required by N.D. Ind. L.R. 56-1(f). ECF 78. Attached to the notice was a copy of Federal Rule of Civil Procedure 56 and Northern District of Indiana Local Rule 56-1. Pursuant to Local Rule 56-1(b), a party opposing a summary judgment motion must, within 28 days after the movant serves the motion, separately file (1) a response brief; and (2) a Response to Statement of Material Facts, which includes a citation to evidence supporting each dispute of fact. On March 6, 2025, the court extended McCracken’s deadline to respond until April 7, 2025, and cautioned him that if he did not file a response by the deadline the court may rule on the summary judgment motion

without a response. ECF 79. This deadline passed over three months ago, but McCracken still has not responded. Therefore I will now rule on the defendants’ summary judgment motion. Summary judgment must be granted when “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Federal Rule of Civil Procedure 56(a). A genuine issue of material fact exists when “the

evidence is such that a reasonable [factfinder] could [find] for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To determine whether a genuine issue of material fact exists, the court must construe all facts in the light most favorable to the non-moving party and draw all reasonable inferences in that party’s favor. Heft v. Moore, 351 F.3d 278, 282 (7th Cir. 2003). However, a party opposing a properly

supported summary judgment motion may not rely merely on allegations or denials in its own pleading, but rather must “marshal and present the court with the evidence she contends will prove her case.” Goodman v. Nat’l Sec. Agency, Inc., 621 F.3d 651, 654 (7th Cir. 2010). “[I]nferences relying on mere speculation or conjecture will not suffice.” Trade Fin. Partners, LLC v. AAR Corp., 573 F.3d 401, 407 (7th Cir. 2009).

The defendants argue summary judgment is warranted in their favor on both of McCracken’s claims because (1) the claims fail on the merits and, regardless, (2) they were not personally involved in either alleged constitutional violation. Section 1983 requires a plaintiff to show more than just a violation of a constitutional right. To recover damages from a defendant, he must also prove that defendant was personally involved in the violation. See Kuhn v. Goodlow, 678 F.3d 552, 555-56 (7th Cir. 2012)

(“§ 1983 liability is premised on the wrongdoer’s personal responsibility”); see also Wolf- Lillie v. Sonquist, 699 F.2d 864, 869 (7th Cir. 1983) (a defendant cannot be liable without “a showing of direct responsibility for the improper action[.]”). Therefore, “[a]n individual cannot be held liable in a § 1983 action unless he caused or participated in an alleged constitutional deprivation.” Kuhn, 678 F.3d at 556 (citing Wolf-Lillie, 699 F.2d at 869). Put otherwise, individuals will only be liable for their own misconduct, unless

they are responsible for creating the peril that leads to the constitutional violation. See Burks v. Raemisch, 555 F.3d 592, 596 (7th Cir. 2009). Failure to intervene claim against Sgt. Hensley McCracken is proceeding against Sgt. Hensley “for failing to intervene in the use of excessive force by Officer John Doe[.]” ECF 14 at 8. Specifically, McCracken alleged in

his complaint that Sgt. Hensley was “standing nearby” and failed to intervene when Officer Doe sprayed McCracken with OC (or oleoresin capsicum) spray. Id. at 2. The amended complaint alleges that the incident happened between the dates of March 15, 2022, and April 15, 2022. ECF 7 at 3. Sgt. Hensley argues she was not personally involved in this claim because

McCracken admitted in his deposition testimony that he was not sure where Sgt. Hensley was located when Officer Doe sprayed him with OC spray. ECF 76 at 4. Specifically, McCracken conceded at his deposition that he was “not for sure” where Sgt. Hensley was located when he was sprayed with OC spray, that she may have been 15-20 feet away in the sallyport, and that she only showed up once a signal was called after the application of OC spray. ECF 75-1 at 34-36. Sgt. Hensley states in her answers

to interrogatories she has no recollection whatsoever of this incident, and does not recall witnessing Officer Doe spray McCracken with OC spray. ECF 71 at 2-4. Here, to survive summary judgment on this claim, McCracken needed to provide evidence that Sgt. Hensley “had a realistic opportunity to intervene to prevent” Officer Doe from deploying OC spray. Lewis v. Downey, 581 F.3d 467, 472 (7th Cir. 2009). It’s undisputed that Sgt. Hensley does not recall witnessing Officer Doe’s use of OC spray,

and that McCracken was “not for sure” where Sgt. Hensley was located when he was sprayed by Officer Doe. Because there is no evidence in the record that Sgt. Hensley was present at the time Officer Doe sprayed McCracken with OC spray, no reasonable jury could conclude (1) she had a realistic opportunity to intervene to prevent Officer Doe from using OC spray or (2) she was otherwise personally involved in this alleged

constitutional violation. For both of these reasons, summary judgment is warranted in favor of Sgt. Hensley on this claim. Conditions of confinement claim against Sgt. Hensley and Sgt. Kirby McCracken is proceeding against Sgt. Hensley and Sgt. Kirby “for denying him the minimal civilized measure of life’s necessities in violation of the Eighth

Amendment[.]” ECF 14 at 8. The Eighth Amendment prohibits inhumane conditions of confinement. Farmer v. Brennan, 511 U.S. 825, 834 (1994). In evaluating a conditions of confinement claim, courts conduct both an objective and a subjective inquiry. Id. On the subjective prong, the prisoner must allege the defendant acted with deliberate indifference to his health or safety. Farmer, 511 U.S. at 834. Specifically, the plaintiff must provide evidence the

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Goodman v. National Security Agency, Inc.
621 F.3d 651 (Seventh Circuit, 2010)
Herbert L. Board v. Karl Farnham, Jr.
394 F.3d 469 (Seventh Circuit, 2005)
Kuhn v. Goodlow
678 F.3d 552 (Seventh Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Lewis v. Downey
581 F.3d 467 (Seventh Circuit, 2009)
Trade Finance Partners, LLC v. AAR CORP.
573 F.3d 401 (Seventh Circuit, 2009)
James Donald v. Wexford Health Sources, Inc.
982 F.3d 451 (Seventh Circuit, 2020)
Gail Stockton v. Milwaukee County, Wisconsin
44 F.4th 605 (Seventh Circuit, 2022)

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McCracken v. Kirby, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccracken-v-kirby-innd-2025.