Morrow v. Heishman

CourtDistrict Court, N.D. Indiana
DecidedJuly 14, 2025
Docket3:25-cv-00211
StatusUnknown

This text of Morrow v. Heishman (Morrow v. Heishman) 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
Morrow v. Heishman, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

TIMOTHY S. MORROW,

Plaintiff,

v. CAUSE NO. 3:25-CV-211-TLS-AZ

T. HEISHMAN, B. MEYERS, McCULLUM, ROGERS, T. HAMRICK, and JOHN DOE,

Defendants.

OPINION AND ORDER Timothy S. Morrow, a prisoner without a lawyer, filed a complaint about prison officials failing to protect him from an attack by his roommate at Miami Correctional Facility. 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) (cleaned up). 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. Morrow details in his complaint how he started reporting on August 25, 2024, that he did not feel safe in his room with his roommate. First, he wrote the Department of Internal Investigations via his tablet. After he got no response, he submitted two requests in his counselor’s box—one on August 26 and one on August 27—asking to be pulled out to talk to her about his not feeling safe in his cell. On August 27, 2024, Counselor Murphy pulled Morrow out and had him fill out a Request for Protection form. Morrow explained that his roommate threatened him with a knife and had robbed him. He said his roommate was affiliated with the Aryan Brotherhood. Counselor Murphy scanned the form and emailed it off, recommending that Morrow be approved for protective custody. Counselor Murphy told Morrow to go wait in the dorm until someone came to get him for the move. That afternoon, E-Squad came to Morrow’s cell to search it at Counselor Murphy’s request. E-Squad found a metal knife. Morrow, however, was not moved and his Protective Custody Request (PC Request) was denied. Around 5:00 the next morning, August 28, 2024, Morrow’s cellmate choked him with both his hands. Then he cut Morrow with a dull razor blade on his upper left shoulder, near his

collarbone. Morrow sues D.I.I. T. Heishman, MHL Rogers, Lieutenant B. Meyers, Captain McCullum, Casework Manager T. Hamrick, and Shift Supervisor John Doe—the officials who denied his PC Request—for failing to protect him from his cellmate.1 The Eighth Amendment imposes a duty on prison officials to “take reasonable measures to guarantee the safety of the inmates.” Farmer v. Brennan, 511 U.S. 825, 832 (1994). When an inmate is attacked by another inmate, the Eighth Amendment is violated only if “deliberate indifference by prison officials effectively condones the attack by allowing it to happen.” Haley v. Gross, 86 F.3d 630, 640 (7th Cir. 1996). The defendant “must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” Farmer, 511 U.S. at 837. “Exercis[ing] poor judgment . . . falls short of

meeting the standard of consciously disregarding a known risk to his safety.” Lewis v. Richards, 107 F.3d 549, 554 (7th Cir. 1997). “[A] complaint that identifies a specific, credible, and

1 Morrow is advised that if this information is not specific enough for the Indiana Department of Correction to identify this Defendant Shift Supervisor John Doe, Morrow will need to use discovery in order to learn the identity of this defendant and file an amended complaint that names this defendant. It is permissible to sue a “placeholder defendant” in federal court, but as a practical matter an unnamed defendant cannot be served with process. See Rodriguez v. McCloughen, 49 F.4th 1120, 1121 (7th Cir. 2022). This defendant must be identified and served within the two-year statute of limitations period and the deadline specified in Federal Rule of Civil Procedure 4(m). Id. Because this incident occurred in August 2024, Morrow has sufficient time to learn this defendant’s identity through discovery without needing the court’s assistance. imminent risk of serious harm and identifies the prospective assailant typically will support an inference that the official to whom the complaint was communicated had actual knowledge of the risk.” Gevas v. McLaughlin, 798 F.3d 475, 481 (7th Cir. 2015). General requests for help, expressions of fear, and even prior attacks are insufficient to alert guards to the need for action. Klebanowski v. Sheahan, 540 F.3d 633, 639–40 (7th Cir. 2008). Morrow has plausibly alleged that those defendants were deliberately indifferent to a substantial risk of harm he faced from his cellmate, and a claim against them may proceed.

Morrow was able to obtain medical care for his injury when his unit went to breakfast. He stopped at the OSB2 Med Window, and the nurse there notified custody staff about the attack. After a lot of apparent administrative missteps, Morrow was removed from his cell later that day and placed in a holding cell until a bed could be found for him. Morrow complains that when he was in the holding cell, he told several prison staff about his property being left in his old cell. But when his property was finally collected and brought to him, all that was left was a cut-up mat, a blanket, and his paperwork. He was, thus, left only with one T-shirt, one pair of socks, one pair of boxers, one blue two-piece outfit, and one towel. He wrote Warden Brian English, among others, on September 10, 2024, about his missing personal property, state property, his mattress, and his clothes. Warden English responded that the clothing officer would

replace his state items that were taken, but Morrow never got replacements. He followed up with Warden English on December 12, 2024, to no avail. Morrow alleges he had to go from August 28, 2024, until February 5, 2025, without a change of clothes. He sues Warden English for not ensuring that he was provided with a change of clothing. The Eighth Amendment prohibits conditions of confinement that deny inmates “the minimal civilized measure of life’s necessities.” Townsend v. Fuchs, 522 F.3d 765, 773 (7th Cir. 2008) (citations omitted). In evaluating an Eighth Amendment claim, courts conduct both an objective and a subjective inquiry. Farmer, 511 U.S. at 834. The objective prong asks whether the alleged deprivation is “sufficiently serious” that the action or inaction of a prison official leads to “the denial of the minimal civilized measure of life’s necessities.” Id. (quotation marks omitted). Although “the Constitution does not mandate comfortable prisons,” Rhodes v. Chapman, 452 U.S. 337, 349 (1981), inmates are entitled to adequate food, clothing, shelter, bedding, hygiene materials, and sanitation. Knight v. Wiseman, 590 F.3d 458, 463 (7th Cir. 2009); Gillis v.

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Related

Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Tommy Ray Lewis v. Thomas D. Richards
107 F.3d 549 (Seventh Circuit, 1997)
Herbert L. Board v. Karl Farnham, Jr.
394 F.3d 469 (Seventh Circuit, 2005)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Townsend v. Fuchs
522 F.3d 765 (Seventh Circuit, 2008)
Klebanowski v. Sheahan
540 F.3d 633 (Seventh Circuit, 2008)
Knight v. Wiseman
590 F.3d 458 (Seventh Circuit, 2009)
David Gevas v. Christopher McLaughlin
798 F.3d 475 (Seventh Circuit, 2015)

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Bluebook (online)
Morrow v. Heishman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morrow-v-heishman-innd-2025.