Parris Davon Edward Tillotson v. Frank Vanihel, Yarber, Jones, Trimmer, Emily Enriquez, Coss, 7 Unknown Officers

Summary

The United States District Court for the Southern District of Indiana screens and dismisses Parris Davon Edward Tillotson’s prisoner civil-rights complaint under 28 U.S.C. § 1915A. The court concludes that the alleged slip-and-fall, medical-care allegations, claims against unnamed officers, and supervisory-liability allegations fail to state a claim under the Eighth Amendment or 42 U.S.C. § 1983. The plaintiff is ordered to show cause by April 17, 2026, why judgment should not issue.

Holdings

1. The complaint failed to state an Eighth Amendment claim against Officers Jones and Trimmer because it alleged, at most, negligence in escorting Tillotson across the wet floor, not subjective awareness of a substantial risk of serious harm.
2. The complaint failed to state an Eighth Amendment deliberate-indifference claim against Nurses Coss and Enriquez because Coss reasonably deferred to the treating physician and Enriquez responded reasonably by obtaining further medical assistance.
3. The claims against the seven unknown officers failed because the complaint contained no factual allegations identifying any unnamed officer's participation in the alleged constitutional deprivation.
4. The claims against Warden Vanihel and Lieutenant Yarber failed because the complaint alleged no facts showing their personal wrongdoing and § 1983 does not impose respondeat superior liability.
5. The complaint was dismissed for failure to state a claim upon which relief can be granted under the prisoner-screening statute, subject to Tillotson's opportunity to show cause before judgment is entered.

Questions Presented

1. Whether the complaint stated an Eighth Amendment claim against Officers Jones and Trimmer based on the alleged failure to prevent Tillotson's fall.
2. Whether the complaint stated an Eighth Amendment deliberate-indifference claim against Nurses Coss and Enriquez based on their responses to Tillotson's pain and injuries.
3. Whether the complaint stated a claim against the seven unknown officers where no facts identified their participation in the alleged wrongdoing.
4. Whether the complaint stated a § 1983 claim against Warden Vanihel and Lieutenant Yarber based only on their supervisory positions and an alleged failure to train.

Disposition

other