Maholmes, Antonio v. Kuzmik, Jafia
3:24-cv-00922
| W.D. Wis. | Apr 24, 2025Background
- Antonio Maholmes, Jr., proceeding pro se, sued various state employees alleging misconduct related to his probation and criminal justice interactions in 2023 and 2024.
- Defendants include Maholmes’s public defender, probation agents, a social worker, and a regional chief.
- Maholmes’s claims included failure to coordinate mental health treatment per state court order, due process violations in probation changes, falsified absconding reports, misrepresentation to secure an arrest warrant, and failure to consider exculpatory evidence in probation investigations.
- The court screened the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A, which requires dismissal if the claims are frivolous, fail to state a claim, or are barred by law.
- The court dismissed all of Maholmes’s claims but allowed him to supplement one specific claim regarding whether he was arrested or prosecuted based on alleged false statements about absconding to Minnesota.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to arrange in-patient treatment as ordered | State employees did not comply with court order | Violation of state, not federal law | Dismissed; not a federal claim |
| Due process violation in probation modification | No hearing before probation conditions changed | Not directly addressed | Dismissed without prejudice under Heck |
| Falsified report regarding absconding to Minnesota | Kuzmik lied, resulting in removal from treatment | Not directly addressed | Dismissed; no federal claim stated |
| Misrepresentation to secure arrest warrant | Kuzmik misrepresented facts to obtain warrant | Not directly addressed | Dismissed, but chance to clarify |
| Mishandling of exculpatory evidence in probation investigation | Kuzmik ignored and misrepresented key facts | Not directly addressed | Dismissed without prejudice under Heck |
Key Cases Cited
- DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (1989) (state generally not constitutionally required to provide medical care to individuals not in custody)
- Estelle v. Gamble, 429 U.S. 97 (1976) (prisoners entitled to medical care under Eighth Amendment only if officials disregard substantial risks to health)
- Heck v. Humphrey, 512 U.S. 477 (1994) (civil rights actions challenging custody or sentence not allowed unless conviction is invalidated)
- Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (pleading standards and right to specific medical treatment in custody)
- Williams v. Wisconsin, 336 F.3d 576 (7th Cir. 2003) (Heck applies to challenges to probation conditions)