Webb v. Neal

CourtDistrict Court, N.D. Indiana
DecidedMay 13, 2025
Docket3:24-cv-00856
StatusUnknown

This text of Webb v. Neal (Webb v. Neal) 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
Webb v. Neal, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

ROBERT M. WEBB,

Plaintiff,

v. CAUSE NO. 3:24-CV-856-GSL-JEM

RON NEAL, et al.,

Defendants.

OPINION AND ORDER Robert M. Webb, a prisoner without a lawyer, filed a complaint. 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) (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. In the complaint, Webb alleges that, on July 8, 2024, he fell into a hole near the walkway in the recreation yard in the presence of Sergeant Stone, and he injured his ankle. On July 28, 2024, Officer Davis agreed to deliver a medical request to a nurse. However, she instead immediately opened the medical request, read it, and never turned it in. Medical staff have told Webb that he’s “good” and that he has no broken bones. His ankle is no longer swollen, but Webb continues to experience numbness, misalignment, and pain. The holes in the recreation yard were present for nearly a year and were covered with rocks after Webb’s fall. Staff and other inmates had informed

Warden Neal about the holes in the recreational yard. Webb wrote to Warden Neal and submitted grievances but did not receive a response from Warden Neal or Grievance Specialist Wildfang. Based on these allegations, Webb seeks money damages from five defendants and to see a physician about his foot and ankle. To start, Webb uses legal terminology that sounds in negligence. However, to state an Eighth Amendment claim regarding unconstitutional conditions of

confinement, a prisoner must allege that the defendant acted with deliberate indifference to his health or safety. Farmer v. Brennan, 511 U.S. 825, 834 (1994). “[N]egligence, gross negligence, or even recklessness as the term is used in tort cases is not enough.” Hildreth v. Butler, 960 F.3d 420, 425–26 (7th Cir. 2020). Instead, the inmate must allege “a culpability standard akin to criminal recklessness.” Thomas v. Blackard, 2

F.4th 716, 722 (7th Cir. 2021). The allegations in the complaint suggest that Warden Neal and Sergeant Stone may have acted with deliberate indifference to the risk of harm posed by the holes in the recreation yard. 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). 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. Litscher, 468 F.3d 488, 493 (7th Cir. 2006). For an Eighth Amendment claim, the alleged deprivation must be “sufficiently serious” that the action or inaction of a prison official leads to “the denial of the

minimal civilized measure of life’s necessities.” Farmer, 511 U.S. at 834. The Seventh Circuit Court of Appeals has considered on a number of occasions whether a slippery surfaces that have caused inmates to slip and fall were sufficiently serious to invoke the Eighth Amendment. In Pyles v. Fahim, 771 F.3d 403, 404 (7th Cir. 2014), the prisoner alleged that the stairs to the shower were regularly slippery due to water tracked from the nearby by showers. The Seventh Circuit found that these

conditions were not sufficiently serious, holding that “slippery surfaces and shower floors in prisons, without more, cannot constitute a hazardous condition of confinement.” Id. at 410. Next, in Anderson v. Morrison, 835 F.3d 681, 682 (7th Cir. 2016), the prisoner alleged correctional staff handcuffed him and ordered him to walk down the stairs that were covered with milk and garbage. The Seventh Circuit concluded that

the prisoner had described sufficiently serious conditions that were distinguishable from Pyle because the stairs were not only slippery but were also strewn with trash and because correctional staff had handcuffed and refused to assist him with negotiating the stairs. Id. at 682-83. And, in Balle v. Kennedy, 73 F.4th 545, 549–50 (7th Cir. 2023), the prisoner alleged that he had fallen on a kitchen floor with “cracks and holes as deep as

four or five inches” and that he was required to carry five-gallon buckets of water from steam kettles to the sink as part of his job. The Seventh Circuit found that these conditions were sufficiently serious to invoke the Eighth Amendment because the act of carrying a bucket of water increased the risk of falling and that a bucket filled with scalding water increased the risk of incurring a serious injury after a fall. Id.at 554-55.

After careful consideration, the court finds that the allegations in the complaint describe conditions that more closely resemble the conditions in Pyle than in Anderson or Balle. Holes in a recreation yard, without more, do not seem any riskier than the slippery staircase in Pyle. Unlike Anderson and Balle, Webb does not suggest that he was required to traverse the area near the holes for his job or on a guard’s command and there were no circumstances frustrating his ability to navigate. Nor do there appear to

be any circumstances, like scalding water, that greatly increased the risk of serious injury incurred as a result of any potential falls. Consequently, the court finds that the holes in the recreation yard as described in the complaint are not a sufficiently hazardous condition to invoke the Eighth Amendment. Webb also asserts a claim against Officer Davis for violating his medical privacy

rights under the Health Information Portability and Accountability Act (HIPAA) by reading his medical request. However, “HIPAA confers no private right of action.” Stewart v. Parkview Hosp., 940 F.3d 1013, 1015 (7th Cir. 2019). Further, the Seventh Circuit has noted that prisoners “at best have very limited privacy rights . . .” and has “not previously held in a published opinion that they enjoy a constitutional right to privacy

in their medical information.” Franklin v. McCaughtry, 110 Fed. Appx. 715, 719 (7th Cir. 2004) (citing Anderson v. Romero, 72 F.3d 518, 522–23 (7th Cir. 1995)). Other circuits that have recognized such a right did so only in “instances that involved the purposeful dissemination of intensely private medical information.” Id.

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Related

Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Berry v. Peterman
604 F.3d 435 (Seventh Circuit, 2010)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Swanson v. Citibank, N.A.
614 F.3d 400 (Seventh Circuit, 2010)
Robert Westefer v. Michael Neal
682 F.3d 679 (Seventh Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Townsend v. Fuchs
522 F.3d 765 (Seventh Circuit, 2008)
Knight v. Wiseman
590 F.3d 458 (Seventh Circuit, 2009)
Grieveson v. Anderson
538 F.3d 763 (Seventh Circuit, 2008)
Christopher Pyles v. Magid Fahim
771 F.3d 403 (Seventh Circuit, 2014)
Mhammad Abu-Shawish v. United States
898 F.3d 726 (Seventh Circuit, 2018)
Tyquan Stewart v. Parkview Hospital
940 F.3d 1013 (Seventh Circuit, 2019)
Scott Hildreth v. Kim Butler
960 F.3d 420 (Seventh Circuit, 2020)
Adrian Thomas v. James Blackard
2 F.4th 716 (Seventh Circuit, 2021)
Anderson v. Morrison
835 F.3d 681 (Seventh Circuit, 2016)

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Bluebook (online)
Webb v. Neal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/webb-v-neal-innd-2025.