Freeman Cole v. Makayla R. Miller, Kristen M. Servais, Alicia M. Dale, Advanced Correctional Healthcare, Inc., and La Crosse County Sheriff's Dept.

Summary

The United States District Court for the Western District of Wisconsin screened Freeman Cole’s 42 U.S.C. § 1983 complaint concerning alleged inadequate medical care, substantial weight loss, and allegedly harmful food while he was a pretrial detainee. The court dismissed the complaint without prejudice for failure to state a claim but granted leave to amend, and it denied or dismissed related requests for transfer, preliminary injunctive relief, and discovery. The court entered the order on April 6, 2026, setting May 6, 2026, as the deadline for an amended complaint.

Holdings

1. The complaint did not state a plausible constitutional claim because allegations of substantial weight loss alone, without facts concerning height, other adverse symptoms, serious suffering, or lasting harm, did not sufficiently establish a risk of serious harm or that defendants failed to take reasonable measures to abate that risk.
2. The allegation that Cole was being given something harmful in his food did not satisfy Federal Rule of Civil Procedure 8 because it was vague and did not identify the persons allegedly responsible for tampering with the food.
3. The court could not order a person detained for a state criminal charge to be transferred to a federal facility, another county jail, or a state correctional facility.
4. Cole could not compel production of purported evidence before the court determined that he could proceed on a viable claim; the discovery request was dismissed without prejudice as premature.

Questions Presented

1. Whether Cole's allegations of substantial weight loss and denial of hospital treatment or additional nutrition plausibly stated a Fourteenth Amendment pretrial-detainee conditions-of-confinement claim.
2. Whether Cole's allegation that he was being given food intended to harm him stated a claim under Federal Rule of Civil Procedure 8.
3. Whether the court could order Cole's transfer from state detention to federal custody or another county or state correctional facility.
4. Whether Cole could obtain discovery or compel production of purported evidence at the screening stage.

Disposition

other