Robinson v. Butler
3:23-cv-01611
N.D. OhioMar 11, 2025Background
- Martin Robinson, an Ohio prisoner and former correctional officer, filed a pro se Section 1983 civil rights lawsuit against 71 defendants, including officials from several Ohio correctional institutions and the American Correctional Association (ACA).
- The court severed and transferred claims related to London, Warren, and Madison Correctional Institutions, leaving only claims about Robinson’s incarceration at Toledo Correctional Institution.
- Robinson alleges threats and assaults due to his status as a former officer, deliberate indifference to medical needs, excessive force, retaliation for grievances, and other policy-related issues during his incarceration at Toledo.
- Defendants moved to dismiss on various grounds including statute of limitations, failure to state a claim, and, for ACA, lack of state action.
- The court addresses motions to dismiss by both Ohio Department of Rehabilitation and Correction (ODRC) defendants and ACA, taking all well-pled facts in plaintiff’s complaint as true for purposes of the motion.
- This ruling grants dismissal of nearly all claims but allows the deliberate indifference claim to proceed against one healthcare administrator (Kroggel).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Supervisory liability of ODRC officials | Officials knew of ongoing harms and failed to intervene | Awareness and failure to act do not establish liability under § 1983 | Claims dismissed (no personal involvement/allegations insufficient) |
| Deliberate indifference to medical needs | Staff knowingly denied accommodations for disabilities, leading to injury | No actionable conduct, at most negligence; some defendants not personally involved | Dismissed against all except health admin. Kroggel; allowed against Kroggel only |
| Retaliation for grievances | Grievances led to retaliation via suspension of grievance rights | Restrictions were authorized, did not chill protected activity | Claim dismissed (no adverse action sufficient for retaliation) |
| ACA liability under § 1983 | ACA’s audit and accreditation played role in constitutional violations | ACA is a private party, not a state actor under any test | Claim dismissed (ACA is not a state actor) |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (sets plausibility standard for federal pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (articulates the pleading standard for Rule 12(b)(6))
- Estelle v. Gamble, 429 U.S. 97 (establishes deliberate indifference standard for prisoner medical claims)
- Farmer v. Brennan, 511 U.S. 825 (clarifies subjective requirement for deliberate indifference under Eighth Amendment)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (state officials in official capacities are not "persons" under § 1983)