Chatman v. Centurion of Minnesota

Background

David Chatman entered Minnesota Correctional Facility—Moose Lake on December 4, 2024. At intake, his blood glucose was severely elevated and he was placed on insulin. Chatman has diabetes and diabetic neuropathy (nerve damage causing numbness in his feet). His cell contained a heat register positioned on the wall above his bed.

On December 9, 2024, Chatman reported to Nurse Rick Elstad that he had fallen asleep with his right foot on the heat register and suffered a burn. Elstad's notes documented Chatman's diabetes and neuropathy diagnosis. Chatman was then seen by Dr. Lynn Stottler, who directed nursing staff to monitor for worsening symptoms. Shortly after, Nurse Practitioner Keri Ovsak noted that the blister from the initial burn had opened and instructed Chatman to watch for signs of infection.

On December 14, 2024, Chatman reported to Nurse Katie Kneisel that he had again fallen asleep against the heater, this time burning his right big toe and left second toe. Kneisel noted multiple blisters, prescribed medication, and instructed monitoring for infection. Later that same day, she noted signs of suspected infection and ordered antibiotics.

On December 26, 2024, Chatman again expressed concern about both feet and reported additional burns. Nurse Elstad and Nurse Practitioner Ovsak both examined him and documented open areas on multiple toes on both feet. His insulin was also increased that day.

On January 1, 2025, Dr. Stottler noted multiple blisters and documented a plan to continue dressings, advising Chatman to leave blister skin intact, and noting that diabetes was poorly controlled. She expressed hope the wounds would heal before Chatman's anticipated release in two to three weeks.

On January 15, 2025, Nurse Practitioner Ovsak observed black dry tissue on multiple toes with no palpable pulses — signs consistent with serious circulatory compromise. She noted concerns about arterial insufficiency and poor glucose control, but concluded that because of Chatman's upcoming release, he would need to follow up with a community provider. Chatman was released on January 21, 2025. On February 12, 2025, two toes on his left foot were amputated. His right big toe was amputated in July 2025.

Procedural History

Chatman filed his complaint on August 7, 2025, asserting claims under 42 U.S.C. § 1983 — the federal civil rights statute allowing individuals to sue state and local officials for constitutional violations — primarily under the Eighth Amendment (prohibiting cruel and unusual punishment). Defendants included employees of the Minnesota Department of Corrections (DOC) and Centurion of Minnesota, LLC, a private company contracting with the DOC to provide medical services.

Both groups of defendants — the State Defendants (Commissioner Paul Schnell, Nurse Elstad, Nurse Practitioner Ovsak, and Nurse Kneisel) and the Centurion Defendants (Centurion of Minnesota, LLC and Dr. Stottler) — moved to dismiss the entire complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint fails to state a plausible legal claim.

In response, Chatman agreed to dismiss without prejudice all claims against Commissioner Schnell, Nurse Kneisel, Centurion of Minnesota, LLC, and the unnamed Doe defendants. He contested dismissal only as to Count I (Eighth Amendment violations) against Elstad, Ovsak, and Stottler.

Legal Standards

Under Rule 12(b)(6), the court accepts all factual allegations in the complaint as true and asks whether the plaintiff has alleged facts that make the claim plausible on its face. Legal conclusions stated as facts are not accepted as true. The complaint need not include detailed facts but must go beyond mere labels or recitations of legal elements.

To state an Eighth Amendment claim under the deliberate indifference standard — applicable to both conditions-of-confinement claims and inadequate-medical-care claims — a plaintiff must allege two components: 1. Objective: The alleged deprivation must be sufficiently serious — denying the minimal civilized measure of life's necessities, or posing an excessive risk to inmate health or safety. 2. Subjective: The official must have actually known of and disregarded that excessive risk.

Deliberate indifference is a high bar. Medical malpractice, negligence, and even gross negligence are insufficient. The standard is compared to criminal recklessness. Mere disagreement with a treatment decision also does not rise to the level of a constitutional violation.

Analysis and Holdings

Count I — Eighth Amendment: Nurse Elstad and Dr. Stottler

Chatman's theory as to Elstad and Stottler was not that they made poor medical judgments, but that they knowingly left him in a cell where repeated serious injury was highly foreseeable, without taking steps to mitigate that known risk — for example, by facilitating a cell change.

Defendants argued that Chatman's repeated injuries were the result of his own failure to follow instruction to avoid the heater, and that it was therefore not foreseeable Elstad or Stottler would bear responsibility. The Centurion Defendants also argued that Dr. Stottler, as a physician rather than a facility administrator, had no legal duty or authority to move Chatman to a different cell.

Judge Tunheim rejected these arguments at the motion-to-dismiss stage. The complaint alleged that Chatman repeatedly raised concerns about the danger posed by the heat register in his cell and that both Elstad and Stottler knew he was suffering repeated wounds as a result — yet he remained in that cell. Taken as true, these allegations were sufficient to plausibly support both the objective element (an excessive risk to health and safety) and the subjective element (actual knowledge and disregard of that risk).

The court denied the motions to dismiss Count I as to Nurse Elstad and Dr. Stottler.

Count I — Eighth Amendment: Nurse Practitioner Ovsak

Chatman's claim against Ovsak was based on inadequate medical care. He alleged that on January 15, 2025 — just six days before his release — Ovsak observed severe signs of circulatory compromise (black dry tissue, no palpable pulses) and documented her own concern about arterial insufficiency, but deferred further treatment to a community provider solely because of Chatman's imminent release date. Three toes were ultimately amputated.

The State Defendants argued that Ovsak's medical decisions were reasonable, pointing to the fact that she increased Chatman's insulin dosage, and that Chatman's claim amounted to a mere disagreement with medical judgment — which is constitutionally insufficient.

Judge Tunheim acknowledged the high bar for Eighth Amendment medical-care claims but concluded that the allegations, accepted as true, were sufficient to survive a motion to dismiss. The court emphasized that Ovsak had witnessed the progression of Chatman's condition, knew of the severe risk to his feet, yet allegedly withheld further treatment not for any clinical reason but because of his upcoming release date — which, if proven, could constitute deliberate indifference rather than mere medical judgment.

The court denied the motion to dismiss Count I as to Nurse Practitioner Ovsak.

Count VIII — State-Law Medical Negligence

Chatman's complaint also included a state-law medical negligence claim (Count VIII) against Elstad, Ovsak, and Stottler. Because Chatman made no arguments in his briefing in support of Count VIII, the court granted the defendants' motions to dismiss as to that count.

Qualified Immunity

The State Defendants raised qualified immunity — a doctrine that shields government officials from civil liability unless they violated a clearly established legal right — but only in a footnote and a single sentence in their reply brief. Judge Tunheim rejected this cursory argument without extended analysis at this stage.

Disposition

- State Defendants' Motion to Dismiss: Denied as to Count I against Nurse Rick Elstad and Nurse Practitioner Keri Ovsak; granted without prejudice as to all other claims. - Centurion Defendants' Motion to Dismiss: Denied as to Count I against Dr. Lynn Stottler; granted without prejudice as to all other claims. - The case proceeds on Count I (Eighth Amendment deliberate indifference) against Elstad, Ovsak, and Stottler only.