Crabtree v. Becker County et al

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
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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.
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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
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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.
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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
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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
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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
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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).
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