EATON v. PLASSE, 2:22-cv-00379

Arsenio Eaton, a pretrial detainee at Vigo County Jail, filed suit against Sheriff John Plasse, alleging unconstitutional conditions from overcrowding at the jail.
Eaton was housed in an overcrowded four-person cell with five inmates, requiring him to sleep on a "boat" (a mattress on the floor) for nearly a year.
Eaton claimed injury to his feet after tripping on the boat, arguing this resulted from the overcrowded conditions.
Sheriff Plasse moved for summary judgment, arguing lack of personal involvement and that the conditions did not amount to a constitutional violation.
Eaton did not respond to the summary judgment motion; as such, the Court considered the defendant's factual assertions as undisputed if supported by the record.
The Court granted summary judgment for Sheriff Plasse, finding no constitutional violation in the conditions described and no evidence of unreasonable or punitive intent by the defendant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was overcrowding and assignment to a boat a constitutional violation?	Conditions were unconstitutional due to overcrowding and sleeping on a mat.	No personal involvement; conditions were not objectively serious or punitive.	Not a constitutional violation; summary judgment for defendant.
Did the Sheriff have personal involvement or responsibility?	Systemic overcrowding ties the Sheriff to the issue.	Sheriff not involved in day-to-day housing assignments.	Systemic issue, but no evidence Plasse acted unlawfully or unreasonably.
Does tripping on the boat and resulting foot injury rise to constitutional deprivation?	Tripping hazard and injury show deprivation.	Single incident of tripping on a mat is not a deprivation of life's necessities.	Tripping incident does not constitute a constitutional deprivation.
Was the Jail's response to overcrowding objectively unreasonable?	Housing situation was unreasonable and punitive.	Overcrowding management is a legitimate, nonpunitive purpose.	Managing overcrowding is legitimate; no evidence of excessive or punitive intent.

Colbert v. City of Chicago, 851 F.3d 649 (7th Cir. 2017) (personal involvement required for § 1983 liability)
Antonelli v. Sheahan, 81 F.3d 1422 (7th Cir. 1996) (systemic jail conditions and senior officials’ liability)
Bell v. Wolfish, 441 U.S. 520 (1979) (legitimacy of administrative needs in jail management)
Rhodes v. Chapman, 452 U.S. 337 (1981) (standard for overcrowding as a constitutional violation)
Duran v. Elrod, 760 F.2d 756 (7th Cir. 1985) (double-celling and constitutional standards)