Richards v. Ind Dept of Corrs

CourtDistrict Court, N.D. Indiana
DecidedOctober 1, 2025
Docket3:25-cv-00517
StatusUnknown

This text of Richards v. Ind Dept of Corrs (Richards v. Ind Dept of Corrs) 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
Richards v. Ind Dept of Corrs, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

DANNY R. RICHARDS,

Plaintiff,

v. CAUSE NO. 3:25-CV-517-HAB-JEM

INDIANA DEPARTMENT OF CORRECTION, et al.

Defendants.

OPINION AND ORDER Danny R. Richards, a prisoner without a lawyer, filed a complaint against the Indiana Department of Correction and eight other individuals because he believes he suffers from a disability that is not being adequately accommodated and because he is dissatisfied with his medical care related to that disability. ECF 1. He seeks both monetary damages and accommodations for his disability. “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. According to the complaint, Richards was diagnosed with Clostridioides difficile (“C. diff”) in August 2008. In February 2009, he underwent a total colectomy. In

September 2009, he had another surgery, which removed 98% of his rectum and a portion of his large intestine. This led to the creation of a “J pouch.” ECF 1 at 5. A J pouch is “a pouch inside the body that allows a person to get rid of stool in the usual way.” https://www.mayoclinic.org/tests-procedures/j-pouch-surgery/about/pac- 20385069 (last visited Sept. 30, 2025). In February 2010, Richards underwent another surgery where the J pouch was connected to what remained of his rectum. Richards

submitted exhibits with his complaint indicating that he had C. diff again in 2019. He believes he has an active C. diff infection yet again, although Dr. Marthakis has indicated otherwise. Whatever the cause, Richards reports that he is suffering from chronic diarrhea, urinary incontinence, incomplete emptying with frequent urination and bowel movements, and leakage from his bladder and J pouch.

Richards is housed in protective custody and, in the cell house, the only restroom available to him is inside his cell. The Indiana Department of Correction (“IDOC”), Assistant Warden Dawn Buss, Assistant Warden Mr. Nowatzke, Unit Team Manager J. Schneider, Maj. Worlord, Sgt. Robinson, and Sgt. Schmitt have allegedly issued an administrative directive or post order that cell doors remain locked during the three

hours of recreation allowed for inmates in Richards’ housing area. The first hour of recreation takes place on the roof. There is not a restroom on the roof, so Richards does not participate in the first hour of recreation and does not get to enjoy fresh air and sunshine. The next two hours of recreation take place inside the cell house’s dayroom. Because his cell door is locked, he does not have immediate access to a restroom. This has caused Richards to urinate and defecate on himself several times.

When this occurs, he has been forced to wait up to twenty or thirty minutes to gain access to his cell and clean up. Therefore, he no longer participates in the second or third hour of recreation. He claims that the Indiana Department of Correction (“IDOC”), Assistant Warden Dawn Buss, Assistant Warden Mr. Nowatzke, UTM Schneider, Maj. Worlord, Sgt. Robinson, and Sgt. Schmitt knows that he suffers from chronic diarrhea, urinary

incontinence, and severe pain, but they have disregarded his need for accommodations to enjoy recreation; namely, access to a restroom without delay. Richards reports that the defendants claim the doors are kept closed due to safety and security concerns. However, the unit has eleven inmate sanitation workers, and they are each allowed to keep their cell doors open from 6 a.m. to 6 p.m., including during recreation. The IDOC

and other named defendants will not make an exception for Richards. They will only allow him to request permission to have his cell door opened so he can use the restroom. But, when he requests that his cell door be opened, he has been yelled at or told that the doors will open at the top of the hour, consistent with policy. Dr. Nancy Marthakis allegedly informed Assistant Warden Buss, UTM Schneider, Sgt. Robinson,

and Sgt. Schmitt that Richards does not suffer from any disability or impairments, his C. diff resolved in 2021, and he only has a chronic illness code, not a disability code. Richards asserts that Dr. Marthakis’ refusal to categorize him as suffering from a disability has resulted in a refusal to accommodate his medical needs by the IDOC and other individual defendants. Richards contends that his C. diff should be treated as a physical impairment that is episodic or in remission. He asserts that he is being denied

access to a program or activity, including recreation and a restroom.

Richards’ ADA and Rehabilitation Act Claims Richards asserts that the IDOC and each of the individual defendants violated the Americans with Disabilities Act (ADA), 42 U.S.C §§ 12131–12134, and section 504 of the Rehabilitation Act, 29 U.S.C. § 794. Title II of the ADA provides that qualified

individuals with disabilities may not “be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity.” 42 U.S.C. § 12132. “Disability” in this context means: “(1) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (2) a record of such an impairment; or (3) being regarded as having such an

impairment.” Steffen v. Donahoe, 680 F.3d 738, 743 (7th Cir. 2012) (citation and internal alteration omitted). Prisons and correctional facilities are public entities within the purview of Title II. See Pa. Dep’t of Corr. v. Yeskey, 524 U.S. 206, 210 (1998). Declaratory and injunctive relief are available under the ADA. Radaszweski ex rel. Radaszewski v. Maram, 383 F.3d 599, 606 (7th Cir. 2004). There is uncertainty about the availability of

monetary damages under the ADA, so where an inmate seeks monetary damages, the Seventh Circuit has suggested replacing a prisoner’s ADA claim with a parallel claim under the Rehabilitation Act, 29 U.S.C`. § 701, because the relief available is “coextensive.” Jaros v. Ill. Dep’t of Corr., 684 F.3d 667, 671–72 (7th Cir. 2012). Under the Rehabilitation Act, damages are available against a state that accepts federal assistance for prison operations, as all states do. Id. To state a claim under the Rehabilitation Act, a

plaintiff must allege that (1) he is a qualified person (2) with a disability and (3) the defendant denied him access to a program, service, or activity or otherwise discriminated against him because of his disability.1 Wagoner v. Lemmon, 778 F.3d 586, 592 (7th Cir. 2015).

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