Allen Cooley, Sr. v. Zachary L. Cole and Kyra D. Woods

Summary

The United States District Court for the Northern District of Indiana held that Allen Cooley, Sr.’s amended prisoner complaint did not state plausible Fourth Amendment claims for excessive force or delayed medical treatment. The court granted Cooley until January 20, 2026, to file a second amended complaint and cautioned that failure to respond would result in dismissal under 28 U.S.C. § 1915A.

Holdings

1. The amended complaint failed to state a plausible Fourth Amendment excessive-force claim because it did not provide facts showing that the officers' actions were objectively unreasonable in the circumstances.
2. Because the alleged events occurred during the period after arrest and before a probable-cause hearing, the denial-of-medical-care claim arose under the Fourth Amendment and was subject to an objective-reasonableness inquiry; the amended complaint failed to state that claim.
3. A complaint must contain sufficient factual matter to state a claim for relief that is plausible on its face; allegations that support only a mere possibility of misconduct are insufficient.
4. The court granted Cooley leave to file a second amended complaint because the defects might be correctable and amendment was not shown to be futile at this stage.

Questions Presented

1. Whether the amended complaint plausibly alleged that the officers used objectively unreasonable force in violation of the Fourth Amendment.
2. Whether the amended complaint plausibly alleged that the officers objectively unreasonably denied or delayed medical care during the period after arrest and before a probable-cause hearing.
3. Whether the court should dismiss the amended complaint under 28 U.S.C. § 1915A or permit another amendment.

Disposition

other