CRUMLEY v. FORESTALL et al
ORDER - DENYING IN PART AND GRANTING IN PART 38 DEFENDANT'S MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS. For the foregoing reasons, the Court DENIES IN PART and GRANTS IN PART Nurse Pierce's Motion for Judgment on the Pleadings (Filing No. 38 ). This action may proceed against her on Crumley's claim under § 1983 but not for injunctive relief. (See Order.) Signed by Judge Tanya Walton Pratt on 1/8/2021. (NAD)
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
KEITH R. CRUMLEY by Next Friend, Shirley
KERRY J. FORESTAL in his Official Capacity as )
Sheriff of Marion County,
MARION COUNTY SHERIFF'S OFFICE,
TERESA PIERCE in her individual capacity,
KHYREE JONES Officer, in his individual
TYLER BOUMA in his individual capacity,
JOANNA SAHM in her individual capacity,
ROBERT D. FREDERICK in his individual
DIEDRA D. BAKER in her individual capacity,
TANESHA S. CREAR in her individual capacity, )
WILLIAM WEAVER in his individual capacity, )
FOXWORTHY Officer (ID 41380), in his
individual capacity, and
CITY OF INDIANAPOLIS,
Case No. 1:19-cv-04110-TWP-DML
ORDER DENYING IN PART AND GRANTING IN PART
DEFENDANT'S MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS
This matter is before the Court on a Motion for Partial Judgment on the Pleadings filed
pursuant to Federal Rule of Civil Procedure 12(c) by Defendant Teresa Pierce, RN ("Nurse
Pierce") (Filing No. 38). 1 Plaintiff Keith R. Crumley ("Crumley") suffers from significant
intellectual disabilities and mental health diagnoses. In his Amended Complaint, he alleges that
This Motion was jointly filed by Nurse Pierce and then-Defendant Correct Care Solutions (aka Wellpath, LLC) (see
Filing No. 38). But after the Joint Stipulation of Dismissal as to a Rehabilitation Act claim against Wellpath, LLC,
(Filing No. 78), and the filing of Crumley's Amended Complaint, which dropped all other claims against Wellpath,
LLC, (Filing No. 81, Filing No. 81-1), the Motion only remains pending as to Nurse Pierce as Wellpath, LLC is no
longer a party to this action (see Filing No. 87).
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he did not receive essential medication and behavioral support while in custody at the Marion
County Jail (the "Jail") after officers of the Indianapolis Metropolitan Police Department ("IMPD")
arrested and detained him after a witness reported him throwing a bottle, (Filing No. 81-1 at 1, 4–
5, 12–15). Pertinent to this Order, Crumley brings claims for monetary and injunctive relief against
Nurse Pierce—who is employed by Correct Care Solutions, an entity responsible for providing
medical care to individuals incarcerated within the Jail—under 42 U.S.C. § 1983. Id. at 4, 16, 20.
For the following reasons, Nurse Pierce's responsive Motion (Filing No. 38) is denied in part and
granted in part.
The following facts are not necessarily objectively true, but as required when reviewing a
motion for judgment on the pleadings, the Court accepts as true the factual allegations in the
Complaint and draws all inferences in favor of Crumley as the non-moving party. See Emergency
Servs. Billing Corp. v. Allstate Ins. Co., 668 F.3d 459, 464 (7th Cir. 2012).
On October 13, 2017, IMPD officers were dispatched to a scene where Crumley, who lived
in group home ("ResCare") because of his diagnosed schizoaffective disorder, intermittent
explosive disorder, and intellectual disabilities, had purportedly thrown a bottle (Filing No. 81-1
at 5–6). When the officers arrived, a ResCare staff member was present but could not provide
much information about Crumley or his needs. Id. at 6. Although a ResCare supervisor arrived a
little later and could offer some more details about Crumley, he was unable to provide identifying
information, such as Crumley's full name or date of birth. Id.
Crumley was then transported by EMS, followed by an IMPD officer, to Eskenazi
Hospital's emergency department ("Eskenazi") for a detention hold and psychological evaluation.
Id. While there, medical staff observed that Crumley struggled to respond to questions and spoke
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at a two-year-old or three-year-old level. Id. Crumley became increasingly agitated and distressed
as he was handcuffed in the holding room, pulling at his hands until they were red, requesting to
"get out of these tapes," yelling to go to restroom every five minutes, and asking "to go home, back
home to my mom." Id. Noting Crumley's struggles and need for one-on-one attention, Eskenazi
staff unsuccessfully requested that IMPD release him from custody. Id. at 7. Eskenazi staff
attempted to establish a crisis intervention and supportive counseling plan, and asked that staff at
the Jail keep Crumley on "self-safety precautions" and that they "closely monitor his behaviors
and medications," which included a prescription for Clozapine (50 mg in the morning and 150 mg
in the evening) and Lithium (450 mg twice daily). Id. at 7, 12. At the hospital, Crumley received
150 mg of Clozapine at 9:32 p.m., 5 mg of haloperidol lactate at 9:36 p.m., and 2 mg of lorazepam
at 9:36 p.m. Id. at 13.
Crumley was then transferred to the Jail. Despite his significant needs documented under
the "mental health segregation" and "mental hazard" codes in Jail records on October 14, 2017,
Crumley was placed in a minimally supervised general population unit. Id. at 8. In this setting,
Crumley struggled to understand the standards, rules, and procedures of the Jail. Id. In the early
morning hours of October 15, 2017, Nurse Pierce created a note in Crumley's records stating that
he was a medical priority because of conditions. She then sent an email to various Jail staff
informing them of this status. Id. at 9. At the same time, Nurse Pierce signed a medical staff
referral form ordering a blood test for Crumley since he was prescribed Clozapine, a drug that
should only be discontinued under a doctor's supervision and in a gradual manner. Id. at 12.
Around noon that day, Crumley fell and injured himself while being transported with other
inmates. Id. at 9. The nurse evaluating Crumley noted that his nose was bleeding, that his ankle
was swollen (and possibly fractured), that he suffered from a mental illness and lived in a group
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home, and that he had not received Clozapine since his arrest three days earlier on October 13,
2017. Id. at 9–10.
Crumley was then transferred back to Eskenazi, where he was treated for his injuries and
released back to the jail. Id. at 10. Around this time, his blood was drawn. Id. at 12. Later that
night—nearly a day after Nurse Pierce sent her email—inmates alerted Jail staff that Crumley
could not take care of himself and requested that he be removed from the general population unit.
Id. at 10. During his time in this unit, Crumley ran into walls, defecated on himself, and did not
speak. Id. Following this report, staff took Crumley for additional medical attention and a mental
health evaluation, eventually placing him in a single cell mental health block on a suicide
segregation code and on heightened supervision. Id. at 10–11.
The next day, October 16, 2017, Crumley was released from the Jail, with Jail staff
informing ResCare staff that he had not received any Clozapine since he was initially at Eskenazi.
Id. at 13. Though he was ordinarily ambulatory, Crumley was brought out of the Jail in a
wheelchair while he cried, curled into the fetal position, and failed to communicate verbally. Id.
Noting these unmissable concerns, along with the fact that he appeared to have an injured face and
stitches on his nose, ResCare transported Crumley directly from the Jail to Eskenazi. Id.
Back at Eskenazi again, Crumley's white blood cell count was found to be outside normal
levels, and he was admitted for in-patient care, ultimately staying there for three days until October
19, 2017. Id. at 13–14. During this hospitalization, physician Dr. Jayme Ahmed observed that
Crumley communicated only with long groans and was incapable of talking or answering
Id. at 14.
Additionally, he exhibited slowed and weakened movement of his
extremities, was unable to lift his arms over his head, and could not walk without assistance. Id.
Examination also revealed a bruised eyelid, a cut on the bridge of his nose, bruising of a shoulder
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and hand, and swelling of an ankle. Id. Dr. Ahmed, who had examined Crumley on October 13,
2017, opined in a medical entry that she noticed a "dramatic difference in his mental state"; and he
was functioning far below his baseline behavior. Id. Moreover, upon his release from Jail,
Crumley "vomited multiple times, was visibly distressed and uncomfortable, his hypertonicity
worsened, his neck was stiff in all directions, and he was in hyperreflexia. He was unable to move
independently and could not even get up to go to the bathroom." Id.
A misdemeanor battery charge against Crumley was dismissed in its entirety, by motion of
the State, on May 30, 2018. Id. at 15. Pertinent to this Order, Crumley brings claims in his
Amended Complaint for monetary and injunctive relief against Nurse Pierce individually, under
42 U.S.C. § 1983, alleging that she "was on notice of, and deliberately indifferent to, the medical
needs of [ ] Crumley," which led to him experiencing "physical pain, bodily injury, mental and
emotional distress, and other damages." Id. at 4, 20.
Though Nurse Pierce moved for partial judgment on the pleadings in response to Crumley's
original Complaint (see Filing No. 38; Filing No. 1), the Court will resolve this motion as it relates
to the Amended Complaint since the claim against Nurse Pierce remains the same (see Filing No.
87 at 1 (noting that the "previously filed Motion for Partial Judgment on the Pleadings only remains
pending as to Nurse Teresa Pierce") (citation omitted)).
Federal Rule of Civil Procedure 12(c) permits a party to move for judgment after the parties
have filed a complaint and an answer, and the pleadings are closed. Rule 12(c) motions are
analyzed under the same standard as a motion to dismiss under Rule 12(b)(6). Pisciotta v. Old
Nat'l Bancorp., 499 F.3d 629, 633 (7th Cir. 2007); Frey v. Bank One, 91 F.3d 45, 46 (7th Cir.
1996). The complaint must allege facts that are "enough to raise a right to relief above the
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speculative level." Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). Although "detailed
factual allegations" are not required, mere "labels," "conclusions," or "formulaic recitation[s] of
the elements of a cause of action" are insufficient. Id. Stated differently, the complaint must
include "enough facts to state a claim to relief that is plausible on its face." Hecker v. Deere &
Co., 556 F.3d 575, 580 (7th Cir. 2009) (internal citation and quotation marks omitted). To be
facially plausible, the complaint must allow "the court to draw the reasonable inference that the
defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing
Twombly, 550 U.S. at 556).
Like a Rule 12(b)(6) motion, the court will grant a Rule 12(c) motion only if "it appears
beyond doubt that the plaintiff cannot prove any facts that would support his claim for relief." N.
Ind. Gun & Outdoor Shows, Inc. v. City of S. Bend, 163 F.3d 449, 452 (7th Cir. 1998) (quoting
Craigs, Inc. v. Gen. Elec. Capital Corp., 12 F.3d 686, 688 (7th Cir. 1993)). The factual allegations
in the complaint are viewed in a light most favorable to the non-moving party; however, the court
is "not obliged to ignore any facts set forth in the complaint that undermine the plaintiff's claim or
to assign any weight to unsupported conclusions of law." Id. (quoting R.J.R. Serv., Inc. v. Aetna
Cas. & Sur. Co., 895 F.2d 279, 281 (7th Cir. 1989)). "As the title of the rule implies, Rule 12(c)
permits a judgment based on the pleadings alone. . . . The pleadings include the complaint, the
answer, and any written instruments attached as exhibits." Id. (internal citations omitted).
Nurse Pierce seeks a judgment on the pleadings with respect to Crumley's claims for
injunctive and monetary relief against her under 42 U.S.C. § 1983. The Court will first address the
§ 1983 claim, before turning to the claim for injunctive relief.
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In the Amended Complaint, Crumley asserts that his claim brought against Nurse Pierce
pursuant to 42 U.S.C. § 1983 proceeds under "the Fourth, Fourteenth and Eighth Amendments to
the United States Constitution." (Filing No. 81-1.) In his reply brief, however, Crumley articulates
that this claim should be analyzed under the Fourth Amendment's "objectively unreasonable"
standard because he "was, at all times relevant, a pretrial detainee." (Filing No. 48 at 4–5.) He
also asserts that the case should additionally be examined under the Fourteenth Amendment,
noting that "[t]he Seventh Circuit has established that a Fourteenth Amendment claim by pretrial
detainee, such as Mr. Crumley, need only establish that the defendant's conduct was objectively
unreasonable." Id. at 11–12 (citation omitted). But these standards do not concurrently apply in
cases: "Before a finding of probable cause, the Fourth Amendment protects an arrestee; after such
a finding, the Fourteenth Amendment protects a pretrial detainee." Pulera v. Sarzant, 966 F.3d
540, 549 (7th Cir. 2020). Crumley asserts under both contentions that he was a "pretrial detainee,"
so it seems the Fourteenth Amendment would apply. See id. But Crumley also argues "that Claims
regarding conditions of confinement for pretrial detainees who have not yet had a judicial
determination of probable cause (a Gerstein hearing), are governed by the Fourth Amendment and
its objectively unreasonable standard," which seems to indicate he was an "arrestee". (Filing No.
48 at 4–5 (emphasis added).)
Crumley's confusion on the applicable standard does not obstruct the Court's determination
of his claim. Either way, because "the standards are now effectively the same for judging the
adequacy of custodial medical care under either Amendment," Pulera, 966 F.3d at 550, the Court
will evaluate the objective reasonableness of Nurse Pierce's conduct. In other words, under both
the Fourth and Fourteenth Amendments, it is Crumley's "burden to provide evidence that [Nurse
Pierce's] actions were 'objectively unreasonable' and caused his injuries." Id. (citing Miranda v.
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Cty. of Lake, 900 F.3d 335, 347, 352 (7th Cir. 2018) (Fourteenth Amendment); Ortiz v. City of
Chicago, 656 F.3d 523, 530 (7th Cir. 2011) (Fourth Amendment)). 2 "Reasonableness," in both
instances, "must be determined in light of the totality of the circumstances." Id. (citations omitted).
Four factors aid the Court in examining this reasonableness of custodial medical care in the context
of the circumstances: (1) a defendant's knowledge "of the arrestee's medical need"; (2) "the
seriousness of the medical need"; (3) "the scope of the requested treatment"; and (4) "police
interests." Williams v. Rodriguez, 509 F.3d 392, 403 (7th Cir. 2007).
Nurse Pierce argues that Crumley fails to state a claim against her under § 1983 because
the facts, as pled, "show that the limited care Nurse Teresa Pierce provided to Mr. Crumley was
adequate and reasonable under the circumstances." (Filing No. 38 at 2.) In her brief, Nurse Pierce
argues that she acted reasonably when, as Crumley acknowledges, she
1) created a note within Mr. Crumley's records to make Mr. Crumley a medical
priority; 2) emailed custody staff informing them that Mr. Crumley was a medical
priority so he could be properly classified and housed within the Marion County
Jail; and 3) signed a medical referral form ordering that Mr. Crumley receive a
blood draw as soon as possible so he could be administered his prescribed
(Filing No. 39 at 11). Indeed, Nurse Pierce continues, Crumley "does not even allege that Nurse
Pierce examined Mr. Crumley," or that she "was responsible for any classification determinations
or for deciding where Mr. Crumley was housed," or that she "had anything to do with the failure
to execute the medical referral signed by Nurse Pierce to get Mr. Crumley a blood draw." Id. She
contends that she "cannot be responsible for the actions or inactions of other individuals" ignoring
her warnings. Id. Nurse Pierce argues that the Amended Complaint contains no allegations of
While the Fourteenth Amendment inquiry includes an additional assessment of whether "medical defendants acted
purposefully, knowingly, or perhaps recklessly when they considered the consequences of their handling of [a
plaintiff's] case," Miranda v. Cty. of Lake, 900 F.3d 335, 353 (7th Cir. 2018), since the parties do not meaningfully
discuss this prong (see Filing No. 39 at 10; Filing No. 48 at 12), the Court will only evaluate the Fourth and Fourteenth
Amendments' shared reasonableness prong.
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objectively unreasonable behavior on her part when she "attempt[ed]to get Mr. Crumley both an
appropriate classification and housing assignment[ ] and referr[ed] Mr. Crumley for a blood draw
so his prescribed medication could be filled." Id. at 12.
In response, Crumley asserts that Nurse Pierce attempts to narrow her "involvement in the
care she provided to Mr. Crumley and evade liability by framing Mr. Crumley's complaint as to
allege that he suffered harm only as a result of other individuals failing to respond to Pierce's
warning about the care Mr. Crumley required." (Filing No. 48 at 5.) This contention, Crumley
argues, disregards his "allegations that Nurse Pierce herself was objectively unreasonabl[e] in her
care of his medical need because she failed to take further steps to ensure and verify that he
received his prescription medications or was moved to a more appropriate unit to meet his needs
as a medical priority." Id. (Emphasis in original.) Crumley further argues that he "had an
objectively serious medical condition in that he required his prescription medications to avoid
physical withdrawal symptoms, and supports for behavioral management." Id. at 11. Because he
"was unable to answer even the most typical interview questions due to his significant intellectual
disability," at Eskenazi—and it "can be reasonably inferred that his level of functioning did not
improve once transferred to jail and during his interaction with Nurse Pierce"—Nurse Pierce
"cannot dispute that she had first-hand knowledge of Mr. Crumley's serious medical and behavioral
needs," especially since "she entered a note in his chart that he was considered to be a medical
priority due to his medical condition and because he received residential supports in the
community." Id. Moreover, instead of her "inaction," "Nurse Pierce had an available avenue to
alert additional medical or custody staff that Mr. Crumley may need to be transported to the
hospital for monitoring of his medical symptoms, medications or other needs."
Id. at 12.
Moreover, "Nurse Pierce had objective knowledge of a serious risk to Mr. Crumley's health and
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safety, yet she acted with disregard of those concerns and simply passed him along to other staff
members rather than ensuring his needs were actually met." Id. at 15.
In reply, Nurse Pierce maintains that Crumley's response brief "appears to paint Nurse
Pierce as an omniscient supervisor of all staff in the Marion County Jail that is responsible for
everything that goes on in the jail 24/7". (Filing No. 49 at 6.) Though Crumley asserts "Nurse
Pierce should have done more to ensure Mr. Crumley was placed in an appropriate housing
assignment," he "does not allege Nurse Pierce was responsible for any classification
determinations or for deciding where Mr. Crumley was housed." Id. But while she tried "to
provide individuals who did do those things with all the appropriate information necessary," she
"cannot be responsible for the actions or inactions of other individuals." Id. at 7. Moreover, while
Crumley argues that Nurse Pierce "should have done more to ensure he was provided adequate
staffing and accommodations," he only alleges that she was involved in his care and "working at
the jail between 1:20 AM and 1:40 AM on October 15, 2017." Id. Further, while Crumley
"attempts to hold Nurse Pierce responsible for not ensuring that" he received his medicine, "she
referred Mr. Crumley for a blood draw ASAP due to his prescription medication." Id. Crumley
"does not allege that Nurse Pierce was the individual who failed to either draw Mr. Crumley's
blood or provide Mr. Crumley with his medication"; instead, he "merely alleges Nurse Pierce took
action to provide appropriate medical care to Mr. Crumley, but her orders and/or recommendations
were not heeded." Id. at 7–8. Further, while Crumley "alleges in a conclusory nature that Nurse
Pierce was on notice of, and 'deliberately indifferent to,' the medical needs of Mr. Crumley," his
"Complaint does not even plead that Nurse Pierce actually had any interaction with Mr. Crumley
whatsoever." Id. at 8 (emphasis in original). Altogether, though Crumley "contends that the
'complaint is devoid of additional actions that Nurse Pierce took to treat or evaluate Mr. Crumley,'"
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Nurse Pierce was not, according to the facts pled in the Amended Complaint, "involved in or
responsible for anything beyond the three referrals and recommendations made between 1:20 AM
and 1:40 AM on October 15, 2017." Id. at 9. At that time, "Nurse Pierce took multiple steps in
an attempt to provide appropriate and reasonable medical care to Mr. Crumley in the form of
attempting to get Mr. Crumley both an appropriate classification and housing assignment, and
referring Mr. Crumley for a blood draw so his prescribed medication could be filled." Id. She
cannot now be held "responsible for everything that happened after her recommendations allegedly
went unheeded regardless of whether she had any role in those determinations, or ever even saw
Mr. Crumley, or was even working at the jail when those determinations were made." Id.
A jury could conclude, based on Crumley's Amended Complaint, that Nurse Pierce acted
objectively unreasonably when she failed to ensure he received vital medication and care. Nurse
Pierce contends that the Amended Complaint does not allege that she "was involved in Mr.
Crumley's care whatsoever beyond that twenty-minute interval." (Filing No. 49 at 6.) But the
absence of her involvement following this period is precisely what could lead to a jury finding she
did not act in an objectively reasonable manner when she did nothing after she elevated Crumley
to a medical priority upon his arrival, emailed other staff members of this prioritized status, and
requested blood work, (see Filing No. 81-1 at 9). At the time of Nurse Pierce's documented
activity, Crumley had already gone two days without Clozapine, medication that, again, should
not be discontinued "without consulting a physician as the recommendation is to decrease the dose
gradually." Id. at 12–13. And after Nurse Pierce's actions, Crumley went another day without this
critical medicine and spent time in the unsupervised general population unit before his release from
the Jail, at which time his condition had precipitously deteriorated. Id. at 13–14. A jury could,
based on these facts, conclude that Nurse Pierce should have done more to aid Crumley in
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receiving the attention he needed. Cf. McCann v. Ogle Cty., Illinois, 909 F.3d 881, 887 (7th Cir.
2018) (holding that a nurse's care of a pretrial detainee suffering from severe burns "was diligent
and attentive"—and objectively reasonable—when she "checked and documented [his] condition
every 5 to 15 minutes, while also regularly changing his bandages, bathing him, and serving him
meals," when she "asked her colleagues to call her day or night if [his] condition worsened" while
off duty, and when she "voluntarily came in on a weekend to assist him with taking a shower").
Similarly, a jury was tasked with determining the objective reasonableness of an officer's
conduct when she created a detainee's "screening record, making note of the fact that [he] suffered
from and took medications for various serious medical conditions," was on duty twice when the
detainee "yelled out a request for a doctor" from her cell, and could infer that because the detainee
"had never left the lockup, she had not had access to any of her medications." Ortiz, 656 F.3d at
532. Likewise, a jury was required to decide the objective reasonableness of two doctors' conduct
after they "deliberately chose a 'wait and see' monitoring plan, knowing that [the detainee] was
neither eating nor drinking nor competent to care for herself." Miranda, 900 F.3d at 354. And a
jury was charged with determining whether two nurses acted in an objectively reasonable way
when one nurse observed blood on a pretrial detainee's "spit mask" but "did not take his vitals or
even touch him" for a several minutes and the other "chose to stand at the nurses' station to observe
[the detainee] rather than render any treatment" before later removing the bloodied mask. Estate
of Perry v. Wenzel, 872 F.3d 439, 458 (7th Cir. 2017). Comparable to the circumstances of these
cases, Crumley, at this stage, has alleged sufficient facts for a jury to conclude that Nurse Pierce's
conduct (or lack thereof) was objectively unreasonable based on her knowledge of Crumley's
exceptionally serious medical needs. Judgment on the pleadings, then, is not warranted, and Nurse
Pierce's Motion is denied as it relates to Crumley's § 1983 claim against her.
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Concerning his claim for injunctive relief, Nurse Pierce asserts that Crumley has
completely failed to respond to her argument that this claim is moot because he is no longer
incarcerated (neither "injunctive" nor "injunction" appear anywhere in his response brief (see
generally Filing No. 48)). The Court agrees and concludes that Crumley has waived any argument
that this claim should not be dismissed. See Crespo v. Colvin, 824 F.3d 667, 674 (7th Cir. 2016)
(A "complete lack of development of [an] argument is sufficient to find waiver."). Accordingly,
Nurse Pierce's Motion is granted as it pertains to injunctive relief against her.
For the foregoing reasons, the Court DENIES IN PART and GRANTS IN PART Nurse
Pierce's Motion for Judgment on the Pleadings (Filing No. 38). This action may proceed against
her on Crumley's claim under § 1983 but not for injunctive relief.
Thomas E. Crishon
INDIANA DISABILITY RIGHTS
Justin C. Schrock
INDIANA DISABILITY RIGHTS
Nikki G. Gray
INDIANA DISABILITY RIGHTS
Carol A. Dillon
BLEEKE DILLON CRANDALL, P.C.
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Christopher Andrew Farrington
BLEEKE DILLON CRANDALL ATTORNEYS
Anthony W. Overholt
FROST BROWN TODD LLC (Indianapolis)
Alexander Phillip Will
FROST BROWN TODD LLC (Indianapolis)
Andrew J. Upchurch
OFFICE OF CORPORATION COUNSEL CITY OF INDIANAPOLIS
Adam Scott Willfond
OFFICE OF CORPORATION COUNSEL CITY OF INDIANAPOLIS
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