0:25-cv-02064•Crabtree v. Becker County et al
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UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Brian Crabtree, Plaintiff, v. Jail Administrators, Becker County, “Nurse Tammy,” “Barb,” and Advanced Correctional Health Care, Defendants. Civil No. 25-CV-2064-JWB-EMB REPORT AND RECOMMENDATION This matter is before the Court on Plaintiff Brian Crabtree’s filing received on November 20, 2025 (“Third Amended Complaint,” Dkt. No. 19.) For the reasons below, the Court recommends dismissing this action and denying as moot Crabtree’s pending applications to proceed in forma pauperis. Crabtree is presently incarcerated at Minnesota Correctional Facility— Moose Lake. (See Docket.) As the Court understands the Third Amended Complaint, Crabtree alleges that he has a “Factor 5 blood [clotting] disorder” and suffers from seizures, and that he was denied necessary medication for these conditions at Becker County Jail in early 2025, resulting in his hospitalization. (Dkt. No. 19 at 1.) Crabtree alleges that the denial of CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 1 of 8
2 medication demonstrated deliberate indifference to his serious medical needs. (Id. at 2.) He seeks to bring an Eighth Amendment claim. (Id. at 1.) Although the Third Amended Complaint lacks a caption, Crabtree provides a list of individuals from whom he seeks damages (Dkt. No. 19 at 1), which this Court will assume are the intended defendants. On that assumption, Crabtree sues as defendants (1) “Nurse Tammy,”1 (2) an individual identified only as “Barb,” (3) Advanced Correctional Health Care (presumably the Becker County Jail’s medical provider), (4) Becker County, and (5) unspecified “jail administrators.” (Id.) The Third Amended Complaint does not specify the capacity in which the individual defendants are sued. For relief, Crabtree seeks over $1 million in damages. (See id.) Rather than pay this action’s filing fee, Crabtree has applied for in forma pauperis (“IFP”) status. (Dkt. Nos. 2, 12.) His applications suggest that he might well financially qualify for IFP status. But under the federal statute governing IFP proceedings, “[n]otwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that . . . the action . . . fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2). 1 Spelled as “Tammy” and “Tammi” in the Third Amended Complaint. CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 2 of 8
3 When determining if a complaint states a claim on which a court may grant relief, a district court accepts the complaint’s factual allegations as true, see, e.g., Varga v. U.S. Bank Nat. Ass’n, 764 F.3d 833, 836 (8th Cir. 2014), drawing all reasonable inferences in the plaintiff’s favor, see, e.g., Loftness Specialized Farm Equip., Inc. v. Twiestmeyer, 742 F.3d 845, 850, 854 (8th Cir. 2014). A complaint’s factual allegations need not be detailed, but they must “raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). A complaint must “‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570); see also Zink v. Lombardi, 783 F.3d 1089, 1098 (8th Cir. 2015) (en banc). “Determining whether a complaint states a plausible claim for relief will . . . be a context-specific task that requires the . . . court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679. Courts should construe pro se complaints “liberally, but the complaint must still allege sufficient facts to support the claims advanced.” Sandknop v. Mo. Dep’t of Corrs., 932 F.3d 739, 742 (8th Cir. 2019) (internal quotation marks and citation omitted). Prison officials violate the Eighth Amendment if they exhibit “deliberate indifference” to an inmate’s “serious medical needs.” Mitchell v. Saint Louis Cnty., 160 F.4th 950, 957 (8th Cir. 2025). To state a deliberate- indifference claim, a prisoner must allege facts showing that (1) he suffered CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 3 of 8
4 from an “objectively serious medical need” and (2) the defendants knew of that need but “‘deliberately disregarded’” it. Id. (quoting Jackson v. Buckman, 756 F.3d 1060, 1065 (8th Cir. 2014)). On the deliberate-indifference prong, an official can be found deliberately indifferent only if he knows of and disregards an excessive risk to inmate health or safety; “the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw that inference.” Vandevender v. Sass, 970 F.3d 972, 975–76 (8th Cir. 2020) (quoting Farmer v. Brennan, 511 U.S. 825, 837 (1994)). The Court will first consider the Complaint’s claims against Becker County and Advanced Correctional Health Care (including any official- capacity claims against those entities’ employees).2 Under 42 U.S.C. § 1983, a local government or private corporation performing a governmental function cannot be held liable solely on a theory of respondeat superior or vicarious liability. Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 691 (1978). It is responsible only for its own unconstitutional acts—for instance, the “execution of a government’s policy or custom” that inflicts an injury. Id. at 694. As a result, to state a claim against Becker County or Advanced 2 The Court assumes for present purposes that “Nurse Tammy” and “Barb” are employees or agents of either Becker County or Advanced Correctional Health Care. CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 4 of 8
5 Correctional Healthcare, Crabtree needed to allege that an official policy, custom, or widespread practice of one of these Defendants was the “moving force” behind the alleged denial of medication. Troupe v. Young, 143 F.4th 955, 973, 974 (8th Cir. 2025) (internal quotation marks and citations omitted). Here, the Third Amended Complaint contains no factual allegations about any policy, custom, training deficiency, or supervisory practice that led to Crabtree being denied medication. The Court therefore recommends dismissing without prejudice any claims against Becker County or Advanced Correctional Health Care (including any official-capacity claims against their employees) for failure to state a claim. This leaves the Third Amended Complaint’s individual-capacity claims. The Court will assume without deciding that Crabtree’s alleged conditions qualify as an “objectively serious medical need.” Mitchell, 160 F.4th at 957. Even so, the Court concludes that Crabtree’s allegations still fall short of stating deliberate indifference by “Nurse Tammy” or “Barb.” First, the Third Amended Complaint’s key mental-state allegation— that “Nurse Tammy and Barb . . . know [Crabtree’s] medical history” does not explain what information these individuals possessed, how they knew it, or whether they understood that Crabtree faced a substantial risk of serious harm without particular medications. (Dkt. No. 19 at 1.) Thus, the complaint CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 5 of 8
6 does not plausibly allege that Nurse Tammy and Barb knew of a current, verified prescription that the jail was obligated and able to provide Crabtree. Second, Crabtree’s statement that “they denied me my meds tell [sic] 2- 21-25” is too vague to plausibly show deliberate disregard rather than administrative delay, miscommunication, or a verification issue. The pleading does not identify the medications at issue or other relevant details (e.g., whether the jail had those medications or whether Crabtree was evaluated by medical staff during the relevant period). Without such facts, the alleged denial of medication is consistent with a nonculpable delay in confirming outside prescriptions or arranging treatment; while such conduct could be negligent, it does not, without more, plausibly show “deliberate indifference.” Finally, the Third Amended Complaint impermissibly attributes conduct to “Tammi + Barb” and globally discusses conduct that “they” engaged in without separating what each individual did. (Dkt. No. 19 at 1.) But Section 1983 liability is personal. So, for example, if “Nurse Tammy” was a nurse who lacked authority to prescribe or override others’ orders, then Crabtree has not alleged facts showing she intentionally refused care within her control. And because the Third Amended Complaint does not identify who “Barb” is or her job duties, it does not plausibly allege that she had responsibility for or authority over medication decisions. The Court therefore CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 6 of 8
7 recommends dismissing the Third Amended Complaint’s individual-liability claims against “Nurse Tammy” and “Barb.” As for any individual-liability claims against unidentified “jail administrators,” the pleading is inadequate. (Dkt. No. 19 at 1.) Crabtree does not explain what the jail administrators did that might trigger their liability. The Court thus recommends dismissing those individual-capacity claims as well. In summary, the Court recommends dismissing all the Third Amended Complaint’s claims. Given that recommendation, the Court also recommends denying Crabtree’s pending IFP applications (Dkt. Nos. 2, 12) as moot. RECOMMENDATION Based upon the foregoing, and on the files, records, and proceedings herein, IT IS HEREBY RECOMMENDED that: 1. This action be DISMISSED WITHOUT PREJUDICE, under 28 U.S.C. § 1915(e)(2), for failure to state a claim. 2. Plaintiff Brian Crabtree’s Applications to Proceed In Forma Pauperis (Dkt. Nos. 2, 12) be DENIED as moot. Dated: January 6, 2026 s/Elsa M. Bullard ELSA M. BULLARD United States Magistrate Judge CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 7 of 8
8 NOTICE Filing Objections: This Report and Recommendation is not an order or judgment of the District Court and is therefore not appealable directly to the Eighth Circuit Court of Appeals. Under Local Rule 72.2(b)(1), “a party may file and serve specific written objections to a magistrate judge’s proposed finding and recommendations within 14 days after being served a copy” of the Report and Recommendation. A party may respond to those objections within 14 days after being served a copy of the objections. See Local Rule 72.2(b)(2). All objections and responses must comply with the word or line limits set forth in Local Rule 72.2(c). CASE 0:25-cv-02064-JWB-EMB Doc. 21 Filed 01/06/26 Page 8 of 8
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