Michael A. Loomis v. Wellpath LLC, Marathon County, Mary Hinson, Jennifer Nowak, Scott Parks, and Debra Gleason

Summary

The United States District Court for the Western District of Wisconsin dismissed Michael A. Loomis’s pro se complaint alleging denial of prescription medication and retaliation during his detention at Marathon County Jail. The court held that the complaint failed to plausibly allege Fourteenth Amendment medical-care, First Amendment retaliation, or municipal-liability claims, declined supplemental jurisdiction over the state-law claims, and allowed Loomis to file an amended complaint by April 29, 2026.

Holdings

1. Loomis failed to plausibly allege that Nowak's conduct or medical-care decision was objectively unreasonable.
2. A plaintiff must plausibly allege each individual defendant's personal involvement in causing the constitutional violation; generalized allegations against officials are insufficient.
3. Loomis failed to plausibly allege that Wellpath or Marathon County maintained a policy or custom that caused the denial of his medication.
4. Loomis failed to state a plausible retaliation claim because he did not identify the defendant, explain how that defendant learned of his medical complaints, or allege how the defendant caused his continued confinement.
5. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction over the related Wisconsin-law negligence and medical-negligence claims.

Questions Presented

1. Whether Loomis plausibly alleged a Fourteenth Amendment claim against the individual defendants for denial of medical care.
2. Whether Loomis plausibly alleged that Wellpath LLC or Marathon County maintained a policy or custom causing the alleged denial of medical care under § 1983.
3. Whether Loomis plausibly alleged a First Amendment retaliation claim based on his medical complaints and continued confinement.
4. Whether the court should exercise supplemental jurisdiction over Loomis's Wisconsin-law negligence and medical-negligence claims after dismissing the federal claims.

Disposition

dismissed