Alexander Weatherspoon v. Kenny, et al.

Summary

The United States District Court for the Northern District of Indiana screened Alexander Weatherspoon’s amended 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A. The court allowed claims to proceed against four defendants for allegedly failing to assign him a bottom bunk and for excessive force involving a taser, while dismissing the remaining claims and defendants. The order was entered on May 12, 2026.

Holdings

1. The amended complaint plausibly alleged a Fourteenth Amendment claim against Captain Miller, Assistant Jail Commander Carrie Morgan, and Chief Deputy Terry Ruley because they allegedly knew of Weatherspoon's seizure disorder and need for a bottom bunk, had authority to reassign him, and failed to do so, causing his injuries.
2. The complaint failed to state claims against the Tippecanoe County Sheriff and the Chief of the Lafayette Police Department based only on their supervisory positions and alleged responsibility to oversee officers.
3. The complaint failed to state damages claims against the jail guards and nurses based on their knowledge of the bunk problem or alleged failure to cause a reassignment.
4. The Tippecanoe County Jail could not be sued under § 1983 because it is a building rather than a person or policy-making entity.
5. The complaint plausibly alleged an excessive-force claim against Officer Clark based on the alleged use of a taser against Weatherspoon after he fell, when he was allegedly injured and not posing a threat.

Questions Presented

1. Whether the amended complaint plausibly alleged a Fourteenth Amendment conditions-of-confinement claim against officials who allegedly knew of Weatherspoon's need for a bottom bunk but failed to reassign him.
2. Whether the complaint stated supervisory-liability claims against high-ranking officials based solely on their positions and alleged general oversight responsibilities.
3. Whether the complaint stated claims against jail guards and nurses based on their knowledge of the bunk problem and alleged failure to secure a bed reassignment.
4. Whether the Tippecanoe County Jail was a suable entity under 42 U.S.C. § 1983.
5. Whether the complaint plausibly alleged a Fourteenth Amendment excessive-force claim against Officer Clark based on the alleged taser use.

Disposition

other