Chatman v. Centurion of Minnesota

This case arises from injuries sustained by David Chatman, a diabetic inmate with peripheral neuropathy (nerve damage causing numbness in his feet), while confined at Minnesota Correctional Facility—Moose Lake. Beginning December 4, 2024, Chatman repeatedly burned his feet on a heat register positioned near his bed, suffering severe blisters and ultimately the amputation of two toes on his left foot (February 2025) and his right big toe (July 2025) after his release.

Chatman filed suit on August 7, 2025, asserting claims under 42 U.S.C. § 1983 (the federal civil rights statute allowing individuals to sue state actors for constitutional violations) against multiple defendants, including employees of the Minnesota Department of Corrections and Centurion of Minnesota, LLC (a private contractor providing medical services to inmates). The operative constitutional theory was deliberate indifference to serious medical needs and unsafe conditions of confinement, in violation of the Eighth Amendment's prohibition on cruel and unusual punishment.

Two groups of defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) — the 'State Defendants' (Commissioner Paul Schnell, Nurse Rick Elstad, Nurse Practitioner Keri Ovsak, and Nurse Katie Kneisel) and the 'Centurion Defendants' (Centurion of Minnesota, LLC, and Dr. Lynn Stottler). In response, Chatman agreed to dismiss without prejudice all claims against Commissioner Schnell, Nurse Kneisel, Centurion, and the unnamed Doe defendants, narrowing the dispute to Count I (Eighth Amendment) against Elstad, Ovsak, and Stottler.

Deliberate Indifference Standard: Judge Tunheim reviewed the applicable Eighth Amendment framework, which requires satisfying both an objective prong (the deprivation must be objectively serious, denying the minimal civilized measure of life's necessities) and a subjective prong (the official must have actually known of and disregarded an excessive risk to inmate health or safety). The standard is demanding — medical malpractice or even gross negligence is insufficient; the conduct must be akin to criminal recklessness.

As to Nurse Elstad and Dr. Stottler, Chatman's theory was not that they made bad medical judgments, but that they knowingly left him in a cell where repeated serious injury was a near certainty given his inability to feel heat in his feet. The defendants argued Chatman's own repeated failure to sleep away from the register broke any chain of liability, and that Dr. Stottler as a physician lacked the authority to move Chatman to a different cell. Judge Tunheim rejected both arguments at the motion-to-dismiss stage, concluding that Chatman's allegations — that he raised concerns about the heat register repeatedly and that both Elstad and Stottler knew of his ongoing injuries but left him in the dangerous cell — were sufficient to state a plausible claim.

As to Nurse Practitioner Ovsak, Chatman alleged that five days before his release she observed black, dead-looking tissue on multiple toes and could not feel pulses in his feet, acknowledged concern about arterial insufficiency and poor glucose-related healing, but declined to escalate treatment because his release was imminent, instead deferring to a future community provider. Judge Tunheim found these allegations plausibly supported deliberate indifference — that she recognized a severe medical risk and consciously disregarded it based on his upcoming release date.

The court briefly addressed and rejected the State Defendants' qualified immunity defense (a doctrine that can shield government officials from personal liability unless they violated a 'clearly established' right), finding it was raised too cursorily — only in a footnote and one sentence — to be decided at this stage.

Count VIII (state-law medical negligence against Elstad, Ovsak, and Stottler) was dismissed because Chatman made no argument defending it in his opposition brief.

Result: Both motions to dismiss were granted in part and denied in part. Count I (Eighth Amendment) survives against Elstad, Ovsak, and Stottler. All other claims, including those against Schnell, Kneisel, Centurion, and the Doe defendants, were dismissed without prejudice (allowing potential refiling). Count VIII was dismissed (without specification of prejudice, though the order language mirrors the other dismissals as 'without prejudice' for 'all other claims').