Sims v. Bah

CourtDistrict Court, E.D. Wisconsin
DecidedSeptember 2, 2025
Docket2:25-cv-01067
StatusUnknown

This text of Sims v. Bah (Sims v. Bah) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sims v. Bah, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

MARIO MARTINE SIMS,

Plaintiff,

v. Case No. 25-cv-1067-bhl

OFFICER BAH,

Defendant.

SCREENING ORDER

Plaintiff Mario Martine Sims, who is currently serving a state prison sentence at the Waupun Correctional Institution and representing himself, filed a complaint under 42 U.S.C. §1983, alleging that his civil rights were violated. This matter comes before the Court on Sims’ motion for leave to proceed without prepaying the full filing fee and to screen the complaint. MOTION TO PROCEED WITHOUT PREPAYING THE FILING FEE Sims has requested leave to proceed without prepaying the full filing fee (in forma pauperis). A prisoner plaintiff proceeding in forma pauperis is required to pay the full amount of the $350.00 filing fee over time. See 28 U.S.C. §1915(b)(1). As required under 28 U.S.C. §1915(a)(2), Sims has filed a certified copy of his prison trust account statement for the six-month period immediately preceding the filing of his complaint and has been assessed and paid an initial partial filing fee of $7.52. Sims’ motion for leave to proceed without prepaying the filing fee will be granted. SCREENING OF THE COMPLAINT The Court has a duty to review any complaint in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity and must dismiss any complaint or portion thereof if the prisoner has raised any claims that are legally “frivolous or

malicious,” that fail to state a claim upon which relief may be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §1915A(b). In screening a complaint, the Court must determine whether the complaint complies with the Federal Rules of Civil Procedure and states at least plausible claims for which relief may be granted. To state a cognizable claim under the federal notice pleading system, a plaintiff is required to provide a “short and plain statement of the claim showing that [he] is entitled to relief.” Fed. R. Civ. P. 8(a)(2). It must be at least sufficient to provide notice to each defendant of what he or she is accused of doing, as well as when and where the alleged actions or inactions occurred, and the nature and extent of any damage or injury the actions or inactions caused. “The pleading standard Rule 8 announces does not require ‘detailed factual allegations,’

but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “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.” Id. at 556. “[T]he complaint’s allegations must be enough to raise a right to relief above the speculative level.” Id. at 555 (internal quotations omitted). ALLEGATIONS OF THE COMPLAINT According to Sims, on September 2, 2024, Officer Bah pulled Sims from his cell because

he could not breathe after OC spray had been sprayed near or in his cell. Sims asserts that, even though he was handcuffed behind his back, Officer Bah failed to secure Sims as he walked down the stairs. Sims asserts that he fell and that the handcuffs became stuck between the stairs, wall, and rail. He states that he suffered damage to his neck and shoulder. Dkt. No. 1. THE COURT’S ANALYSIS Under the Eighth Amendment, “prison officials must take reasonable measures to ensure an inmate’s safety.” Christopher v. Buss, 384 F.3d 879, 882 (7th Cir. 2004) (citing Farmer v. Brennan, 511 U.S. 825, 832 (1994)). “To state a claim premised on prison officials’ failure to protect him from harm, [a plaintiff] must allege that the defendants knew of and disregarded an ‘excessive risk’ to his ‘health and safety.’” Id. (citing Farmer, 511 U.S. at 837). While the Seventh

Circuit has acknowledged that walking down a typical stairwell while handcuffed might be riskier than descending without restraints, it has held that the risk is not sufficiently serious to support an Eighth Amendment claim. See Perkins v. Pfister, 711 F. App’x 335, 337 (7th Cir. 2017). The mere fact that Officer Bah’s alleged failure to secure Sims may have violated prison policy is also insufficient to support a constitutional claim. See Scott v. Edinburg, 346 F.3d 752, 760 (7th Cir. 2003) (explaining that §1983 “protects plaintiffs from constitutional violations, not violations of state laws or, in this case, departmental regulations and police practices”). If Sims wants to pursue a negligence claim against Officer Bah, he may do so in state Court. The Court offers no opinion on the merit of a such a claim. The Seventh Circuit has explained that the norm is to afford a plaintiff at least one opportunity to amend his complaint. See Zimmerman v. Bornick, 25 F.4th 491, 494 (7th Cir. 2022). Accordingly, if Sims believes he can cure the deficiencies identified in this decision, he may file an amended complaint by September 26, 2025. He is advised that an amended complaint will

replace the original complaint and must be complete in itself without reference to the original complaint. See Duda v. Bd. of Educ. of Franklin Park Pub. Sch. Dist. No. 84, 133 F.3d 1054, 1056–57 (7th Cir. 1998). If an amended complaint is received by the deadline, the Court will screen it as required by 28 U.S.C. §1915A. If an amended complaint is not received, the Court will dismiss this action based on Sims’ failure to state a claim in his original complaint. If Sims does not believe he can cure the deficiencies identified in this decision, he does not have to do anything further. The Court will enclose an amended complaint form along with this decision. IT IS THEREFORE ORDERED that Sims’ motion for leave to proceed in forma pauperis (Dkt. No. 2) is GRANTED. IT IS FURTHER ORDERED that on or before September 26, 2025, Sims may file an

amended complaint if he believes he can cure the defects in the original complaint as described in this decision.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Dennis W. Christopher v. Edward Buss
384 F.3d 879 (Seventh Circuit, 2004)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Alvin T. Perkins, Jr. v. Randy Pfister
711 F. App'x 335 (Seventh Circuit, 2017)
Mitchell Zimmerman v. Glenn Bornick
25 F.4th 491 (Seventh Circuit, 2022)

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Sims v. Bah, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sims-v-bah-wied-2025.