Albert K. Webb v. Brian English, Leann Ivers, Becker, IDOC, Assoc. Warden, Lambert

Summary

The United States District Court for the Northern District of Indiana screened Albert K. Webb’s prisoner complaint under 28 U.S.C. § 1915A. The court concluded that the alleged slip-and-fall, delay in assistance, and subsequent medical-transport allegations did not plausibly establish deliberate indifference under the Eighth Amendment, but granted Webb until March 31, 2026, to file an amended complaint.

Holdings

1. A slip and fall on a wet floor, without additional extenuating circumstances and without plausible allegations that a defendant had actual knowledge of and disregarded the risk, does not state an Eighth Amendment conditions-of-confinement claim.
2. A defendant cannot be held liable under § 1983 for a constitutional violation unless the defendant caused or participated in the alleged violation.
3. Allegations of negligence, gross negligence, or tort-law recklessness do not state an Eighth Amendment deliberate-indifference claim, and sparse allegations lacking facts connecting a defendant to the alleged deprivation are insufficient.
4. A pro se plaintiff should ordinarily be allowed to amend a deficient complaint at an early stage when amendment would not necessarily be futile.

Questions Presented

1. Whether the allegations concerning a slip and fall on a wet prison floor stated an Eighth Amendment conditions-of-confinement claim.
2. Whether the alleged thirty-minute delay before Webb received assistance stated an Eighth Amendment claim against the named defendants.
3. Whether the allegations concerning post-incident medical care and transportation stated an Eighth Amendment deliberate-indifference claim.
4. Whether Webb should be granted leave to amend the deficient complaint.

Disposition

other