Helmueller Sovereign Freeman v. Drehmel
2:23-cv-00568
E.D. Wis.Aug 6, 2024Background
- Freeman, an inmate at Waupun Correctional Institution, alleged that Correctional Officer Drehmel opened his cell door, enabling another inmate to assault him.
- Freeman had been moved to a single cell after reporting threats from his cellmate.
- Video evidence showed sustained, hostile interactions between Freeman and another inmate before the cell door was opened.
- The sergeant’s cage, where Drehmel was assigned, is the only location from which doors can be remotely opened; no record shows who operated the controls at the critical time.
- Freeman suffered physical injury during the assault; Drehmel denied recollection of opening the door and denied wrongful intent.
- The case is at the summary judgment stage, with Drehmel seeking dismissal and asserting qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment Failure to Protect | Drehmel knew or should have known opening the door allowed a serious risk of harm | No evidence Drehmel knew of specific risk; any action was at most negligent | Sufficient evidence for a jury to find deliberate indifference; summary judgment denied |
| Qualified Immunity | Right to be protected from inmate violence was clearly established | Actions did not violate a clearly established right; entitled to immunity | Denied; right was clearly established and fact dispute remains |
| Discovery Responses (Motion to Compel) | Insufficient discovery responses | All requests properly answered | Denied; Freeman did not reply or contest responses |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Summary judgment standard)
- Farmer v. Brennan, 511 U.S. 825 (Deliberate indifference and Eighth Amendment liability)
- Hudson v. Palmer, 468 U.S. 517 (Right to safety from inmate violence clearly established)
- Pearson v. Callahan, 555 U.S. 223 (Qualified immunity standard)
- Harlow v. Fitzgerald, 457 U.S. 800 (Qualified immunity for government officials)
- Foley v. City of Lafayette, 359 F.3d 925 (Drawing all reasonable inferences in favor of non-moving party at summary judgment)