William James Ray v. T. Worden, et al.

CourtDistrict Court, N.D. Indiana
DecidedFebruary 23, 2026
Docket3:24-cv-00449
StatusUnknown

This text of William James Ray v. T. Worden, et al. (William James Ray v. T. Worden, et al.) 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
William James Ray v. T. Worden, et al., (N.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

WILLIAM JAMES RAY,

Plaintiff,

v. CAUSE NO. 3:24-CV-449-PPS-APR

T. WORDEN, et al.,

Defendants.

OPINION AND ORDER William James Ray, a prisoner without a lawyer, filed an amended complaint.1 ECF 38. “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, I 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. Ray alleges that, on July 1, 2022, he was working in the Miami Correctional Facility (“MCF”) kitchen. John Doe, an Aramark employee and kitchen worker, oversaw the part of the kitchen where Ray worked. This included making sure inmates

1 Ray has presented several different amended complaints (ECF 30; ECF 34; ECF 36; ECF 38), but “[w]hen a plaintiff files an amended complaint, the new complaint supersedes all previous complaints and controls the case from that point forward.” Massey v. Helman, 196 F.3d 727, 735 (7th Cir. 1999). Therefore, Ray’s amended complaint filed August 12, 2025, (ECF 38) is the operative complaint. did not assault each other with items found in the kitchen. John Doe found some chicken hidden in the area where Ray worked. Ray represents that inmates who work

in the kitchen planned to take the chicken with them back to the dorm, which they would then sell to other inmates. John Doe told the inmates that, because of the chicken found hidden near where Ray works, no one would be allowed to take chicken back to their dorms unless someone confessed to stealing the hidden chicken. Ray asserted that he was innocent. Inmates then threatened to assault him. John Doe allegedly knew of the threats and left the area. Ray was assaulted with metal items from the kitchen. Ray

alleges that John Doe deliberately left the area to allow the assault to occur. 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 (citation omitted)). 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. “Exercising 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 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). Giving Ray the benefit of all plausible inferences, he has stated a claim against the John Doe Aramark Employee / Worker present on July 1, 2022. While the assault was taking place, Jane Doe, another Aramark Employee/Worker assigned to another area of the kitchen, walked in and saw what was happening. She did not tell the inmates to stop, and she did not immediately press her emergency call button. She turned around and tried to leave, but Ray and another

inmate fell into her. At that point, she called for backup. Once an offender is under attack, an officer cannot just stand by and do nothing. See Borello v. Allison, 446 F.3d 742, 748-49 (7th Cir. 2006) (noting Eighth Amendment violation can occur where prison official “did not respond to actual violence between inmates”). On the other hand, “correctional officers who are present

during a violent altercation between prisoners are not deliberately indifferent if they intervene with a due regard for their safety[.]” Shields v. Dart, 664 F.3d 178, 181 (7th Cir. 2011). Ray alleges that Jane Doe did not act quick enough, but she did not do nothing. She called for backup before she was able to leave the room. Therefore, Ray may not proceed on this claim against the Jane Doe Aramark Employee/Worker.

This same Jane Doe defendant wrote a conduct report accusing Ray of assaulting her. Jane Doe claimed that the inmates were merely defending themselves against Ray. The other inmates were not written up for assaulting Ray. He claims this occurred because Jane Doe is white, has made racist remarks in the past, and was involved in an inappropriate relationship with one of the white inmates that was assaulting him.

Allegations of false disciplinary reports do not state a claim where due process is afforded, and Ray does not allege any due process deficiencies occurred following the allegedly false charge. See Hanrahan v. Lane, 747 F.2d 1137, 1140–41 (7th Cir. 1984). Therefore, he may not proceed against the Jane Doe Aramark Employee/Worker. Officers stopped the assault, and Ray was taken to the medical department for treatment. The inmates who allegedly assaulted him, however, were not disciplined.

Ray alleges that a John or Jane Doe Aramark Employee/Supervisor knew that the inmates that attacked Ray wanted to attack him again because the inmates were yelling threats at Ray as he was removed from the kitchen. John or Jane Doe Aramark Employee/ Supervisor also knew that, when the inmate kitchen workers left the kitchen, they would need to walk past the medical department where both the

supervisor and the inmates allegedly knew Ray was located. One of the inmates who assaulted Ray in the kitchen entered the medical area and stabbed Ray in the leg. Ray contends that, because this risk was known to the John or Jane Doe Aramark Employee/Supervisor, they should have had the inmates that assaulted Ray escorted from the kitchen by custody staff to prevent this attack.

Here, the possibility that an inmate would enter the medical department without a pass to attack Ray a second time after some unspecified amount of time had passed is far too speculative to allow a plausible inference that the John or Jane Doe Aramark Employee/Supervisor consciously disregarded a known risk to Ray’s safety.

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Estelle v. Gamble
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515 U.S. 472 (Supreme Court, 1995)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Michael Hanrahan v. Michael P. Lane
747 F.2d 1137 (Seventh Circuit, 1984)
Curtis Shields v. Thomas Dart
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675 F.3d 703 (Seventh Circuit, 2012)
Tommy Ray Lewis v. Thomas D. Richards
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112 F.3d 262 (Seventh Circuit, 1997)
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196 F.3d 727 (Seventh Circuit, 2000)
Herbert L. Board v. Karl Farnham, Jr.
394 F.3d 469 (Seventh Circuit, 2005)
Donald F. Greeno v. George Daley
414 F.3d 645 (Seventh Circuit, 2005)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Burks v. Raemisch
555 F.3d 592 (Seventh Circuit, 2009)
Klebanowski v. Sheahan
540 F.3d 633 (Seventh Circuit, 2008)
Jackson v. Kotter
541 F.3d 688 (Seventh Circuit, 2008)
David Gevas v. Christopher McLaughlin
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