Travis Hollsten v. Amy Toddish, Jessica Standke, Jamie Vander Sanden, Kurt Sadowska, Grant Rucinski, Nicholas Baatz, Brian Cahak, Johnathan Christianson, Todd Gillingham, Sarah Feltes, Mark Harper, Ashley Walther, John Doe, and Ryan Kuepper

CourtDistrict Court, E.D. Wisconsin
DecidedJanuary 27, 2026
Docket2:24-cv-01543
StatusUnknown

This text of Travis Hollsten v. Amy Toddish, Jessica Standke, Jamie Vander Sanden, Kurt Sadowska, Grant Rucinski, Nicholas Baatz, Brian Cahak, Johnathan Christianson, Todd Gillingham, Sarah Feltes, Mark Harper, Ashley Walther, John Doe, and Ryan Kuepper (Travis Hollsten v. Amy Toddish, Jessica Standke, Jamie Vander Sanden, Kurt Sadowska, Grant Rucinski, Nicholas Baatz, Brian Cahak, Johnathan Christianson, Todd Gillingham, Sarah Feltes, Mark Harper, Ashley Walther, John Doe, and Ryan Kuepper) 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
Travis Hollsten v. Amy Toddish, Jessica Standke, Jamie Vander Sanden, Kurt Sadowska, Grant Rucinski, Nicholas Baatz, Brian Cahak, Johnathan Christianson, Todd Gillingham, Sarah Feltes, Mark Harper, Ashley Walther, John Doe, and Ryan Kuepper, (E.D. Wis. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

TRAVIS HOLLSTEN,

Plaintiff, Case No. 24-CV-1543-JPS-JPS v.

AMY TODDISH, JESSICA STANDKE, ORDER JAMIE VANDER SANDEN, KURT SADOWSKA, GRANT RUCINSKI, NICHOLAS BAATZ, BRIAN CAHAK, JOHNATHAN CHRISTIANSON, TODD GILLINGHAM, SARAH FELTES, MARK HARPER, ASHLEY WALTHER, JOHN DOE, and RYAN KUEPPER,

Defendants.

Plaintiff Travis Hollsten (“Plaintiff”), a former inmate, filed a pro se complaint under 42 U.S.C. § 1983 alleging that Defendants Amy Toddish (“Toddish”), Jessica Standke (“Standke”), Jamie Vander Sanden (“Vander Sanden”), Kurt Sadowska (“Sadowska”), Grant Rucinski (“Rucinski”), Nicholas Baatz (“Baatz”), Brian Cahak (“Cahak”), Johnathan Christianson (“Christianson”), Todd Gillingham (“Gillingham”), Sarah Feltes (“Feltes”), Mark Harper (“Harper”), Ashley Walther (“Walther”), John Doe, and Ryan Kuepper (“Kuepper”)1 violated his constitutional rights. ECF No. 1. On April 30, 2025, the Court screened Plaintiff’s amended complaint and allowed Plaintiff to proceed on the following three claims: (1) Eighth

1Plaintiff initially identified Kuepper as “The Unit W IUS”; counsel for the Defendants identified Kuepper when accepting service on his behalf. ECF No. 14. Amendment deliberate indifference claim against Defendants Toddish, Standke, Vander Sanden, Sadowska, Rucinski, Baatz, Cahak, Christianson, Gillingham, Feltes, Harper, Walther, John Doe, and Kuepper for knowingly keeping Plaintiff past his release date; (2) Fourteenth Amendment due process claim against Defendants Toddish, Standke, Vander Sanden, Sadowska, Rucinski, Baatz, Cahak, Christianson, Gillingham, Feltes, Harper, Walther, John Doe, and Kuepper for knowingly keeping his past his release date; and (3) First Amendment retaliation claim against Defendants Vanden Sander, Harper, Walther, Kuepper, Rucinski, Feltes, Christianson, and Baatz. ECF No. 9 at 10. Prior to Defendants’ appearance, Plaintiff filed a motion for summary judgment because no facts were in dispute. ECF No. 10. The Court will deny this motion because it was premature. On July 7, 2025, Defendants filed a motion for summary judgment, arguing that Plaintiff failed to exhaust his administrative remedies as to all the claims in this case. ECF No. 28.2 The Court will grant Defendants’ motion for an extension of time to file summary judgment based on exhaustion and therefore finds the motion timely. On July 14, 2025, Plaintiff filed a brief in opposition, ECF No. 32, and a motion to amend the complaint, ECF No. 33. On July 28, 2025, Defendants filed a reply that also addresses Plaintiff’s motion to amend the complaint. ECF No. 36. The

2Defendant Toddish and John Doe did not file for summary judgment in this case. See ECF No. 28. However, Defendants indicate that if the motion for summary judgment is successful, the Court should dismiss the claims against these defendants based on Plaintiff’s failure to exhaust administrative remedies. ECF No. 29 at 1 n.1. The Court agrees because Plaintiff was provided notice and reasonable time to respond to any argument that he exhausted his administrative remedies with respect to these defendants. See Fed. R. Civ. P. 56(f)(1). motion for summary judgment is now fully briefed and ready for disposition. For the reasons explained below, the Court will grant Defendants’ motion for summary judgment based on the failure to exhaust administrative remedies and this case will be dismissed without prejudice. As a preliminary matter, however, the Court will deny Plaintiff’s motion to amend the complaint because amendment would be futile. Federal Rule of Civil Procedure 15 provides that the Court freely grant leave to amend when justice so requires. Here, Plaintiff seeks to add a claim against Judge Zakowski for wrongly delaying his release from custody. However, amendment would but futile in this instance because, as discussed below, Plaintiff failed to properly exhaust his administrative remedies for the claims in this case. Moreover, Plaintiff’s claims against Judge Zakowski appear to likely be barred by judicial immunity. See John v. Barron, 897 F.2d 1387, 1391 (7th Cir. 1990) (Judges not liable in civil actions for their judicial acts unless they have acted in the clear absence of all jurisdiction.). As such, the Court will deny Plaintiff’s motion to amend the complaint. 1. STANDARD OF REVIEW 1.1 Summary Judgment Federal Rule of Civil Procedure 56 provides that the Court “shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); Boss v. Castro, 816 F.3d 910, 916 (7th Cir. 2016). A fact is “material” if it “might affect the outcome of the suit” under the applicable substantive law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute of fact is “genuine” if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. The Court construes all facts and reasonable inferences in the light most favorable to the non-movant. Bridge v. New Holland Logansport, Inc., 815 F.3d 356, 360 (7th Cir. 2016). 1.2 Exhaustion of Prisoner Administrative Remedies The Prison Litigation Reform Act (“PLRA”) establishes that, prior to filing a lawsuit complaining about prison conditions, a prisoner must exhaust “such administrative remedies as are available.” 42 U.S.C. § 1997e(a). To do so, the prisoner must “file complaints and appeals in the place, and at the time, the prison’s administrative rules require.” Pozo v. McCaughtry, 286 F.3d 1022, 1025 (7th Cir. 2002). He must do so precisely in accordance with those rules; substantial compliance does not satisfy the PLRA. Id.; Burrell v. Powers, 431 F.3d 282, 284–85 (7th Cir. 2005). A suit must be dismissed if it was filed before exhaustion was complete, even if exhaustion is achieved before judgment is entered. Perez v. Wis. Dep’t of Corr., 182 F.3d 532, 535 (7th Cir. 1999). The exhaustion requirement furthers several purposes, including restricting frivolous claims, giving prison officials the opportunity to address situations internally, giving the parties the opportunity to develop the factual record, and reducing the scope of litigation. Smith v. Zachary, 255 F.3d 446, 450–51 (7th Cir. 2001). Failure to exhaust administrative remedies is an affirmative defense to be proven by a defendant. Westefer v.

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Travis Hollsten v. Amy Toddish, Jessica Standke, Jamie Vander Sanden, Kurt Sadowska, Grant Rucinski, Nicholas Baatz, Brian Cahak, Johnathan Christianson, Todd Gillingham, Sarah Feltes, Mark Harper, Ashley Walther, John Doe, and Ryan Kuepper, Counsel Stack Legal Research, https://law.counselstack.com/opinion/travis-hollsten-v-amy-toddish-jessica-standke-jamie-vander-sanden-kurt-wied-2026.