Crain v. Reagle, 3:25-cv-00095

Durell T. Crain, an inmate, filed an amended complaint and several urgent motions requesting a preliminary injunction, alleging his life and health were in danger due to a plot to murder him and exposure to smoke that aggravated his medical conditions.
Crain sought an immediate transfer to protective custody at Indiana State Prison and eventually out of state, asserting current prison staff were complicit in endangering him.
The court previously allowed Crain to proceed against Warden Smiley for potential permanent injunctive relief under the Eighth Amendment and ordered expedited briefing on the preliminary injunction.
Prison officials denied the alleged plot but indicated Crain was housed in restrictive, single-cell conditions with extensive supervision and security measures.
The court also addressed a series of other motions from Crain, characterizing most as improper requests to take judicial notice of facts not generally known or easily verified.
The judge denied all motions for preliminary injunctive relief and warned Crain against filing repetitive, frivolous motions, placing the case on hold pending standard prisoner litigation screening.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preliminary injunction to ensure safety	There is a murder plot and prison staff are facilitating or ignoring threats to his life/health; seeks immediate transfer to protective custody or out of state	Warden Smiley: There is no plot; safety is ensured	Denied; reasonable measures in place, no likelihood of harm
Deliberate indifference under Eighth Amendment	Officials are not taking adequate steps to protect him from known, specific threats	Steps taken (restrictive housing, staff supervision)	Denied; Eighth Amendment standard not met
Judicial notice of alleged facts	Court should take notice of various incidents and inmate statements as factual or urgent evidence	Most facts not judicially noticeable; not necessary	Denied; inappropriate use of judicial notice
Substitution of party for injunctive relief	Commissioner should replace Warden as defendant to grant the broad relief requested	Warden is proper as current placement authority	Denied; substitution unnecessary at this phase

Mazurek v. Armstrong, 520 U.S. 968 (extraordinary standard for preliminary injunctions)
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (elements required for preliminary injunction)
Farmer v. Brennan, 511 U.S. 825 (Eighth Amendment duty to protect inmates from harm)
Haley v. Gross, 86 F.3d 630 (deliberate indifference standard for prison official liability)
Lewis v. Richards, 107 F.3d 549 (poor judgment or negligence is insufficient to show deliberate indifference)
Grieveson v. Anderson, 538 F.3d 763 (acknowledgment of general danger inherent in prisons)
Klebanowski v. Sheahan, 540 F.3d 633 (general fears, uncorroborated claims insufficient to show deliberate indifference)
Westefer v. Neal, 682 F.3d 679 (injunctive relief in prisons must be narrowly drawn)