Crutcher v. Castelan
2:25-cv-00492
E.D. Wis.May 20, 2025Background
- Andrew Crutcher, an inmate at New Lisbon Correctional Institution, filed a pro se complaint under 42 U.S.C. §1983, alleging civil rights violations at Racine County Jail.
- Crutcher claimed that psychologist Brittany Perez (not a defendant) coerced him to sell contraband and threatened to falsely accuse him of sexual abuse if he refused.
- Crutcher reported these threats and coercion to jail officers Juan Castelan and Nathan Arjon, who allegedly promised to inform jail administration but took no action.
- Crutcher alleged that these failures to intervene exposed him to continued risk and emotional stress, asserting claims against Castelan, Arjon, Racine County Sheriff Christopher Schmaling, and Vital Core Health Care Strategies (Perez’s employer).
- The court screened the complaint as required for prisoner civil rights cases under 28 U.S.C. §1915A, and denied Crutcher’s request to proceed in forma pauperis as moot due to his payment of the filing fee.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to protect from Perez's threats | Castelan and Arjon failed to protect from risk of false sexual abuse accusations | No actual false accusation or sexual abuse occurred | No claim stated as no actual harm occurred |
| Failure to intervene in extortion scheme | Castelan and Arjon did not act on knowledge of Perez’s extortion | Not detailed; case at screening phase | Sufficient to state a failure-to-protect claim |
| Failure to train staff (Schmaling & Vital Core) | Schmaling and Vital Core failed to adequately train/report PREA violations | No facts showing connection between alleged lack of training and harm | No claim stated; claims dismissed |
| Involvement of Perez herself | Not pursuing claim against Perez directly | N/A | Not considered by the court |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for claims under Rule 8)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for stating a claim)
- Miller v. Smith, 220 F.3d 491 (liability for failing to intervene in another official’s misconduct)
- Babcock v. White, 102 F.3d 267 (no compensation for exposure to risk without actual harm)
- Gentry v. Duckworth, 65 F.3d 555 (§1983 does not allow respondeat superior liability for supervisors)