UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

SOUTH BEND DIVISION

QUINTIN J. MAYWEATHER-BROWN, 

 Plaintiff,

v. CAUSE NO.: 3:14-CV-2089-JD-MGG

STEFFANY BIGLER, et al.,

 Defendants.

OPINION AND ORDER

Quintin J. Mayweather-Brown, a prisoner without a lawyer, is proceeding

against Lieutenant Steffany Bigler, Captain John Perry, and Gary Yoder for failing to 

provide him with appropriate conditions of confinement, including adequate clothing, 

bedding, and heat while housed at the Elkhart County Jail (“Elkhart Jail”) in violation of 

the Fourteenth Amendment. (ECF 32; 143.) He is also proceeding against Lieutenant 

Bigler, Captain Perry, Dr. Josh Mathew, Robbin Yohn, and Mr. Yoder for failing to 

provide him with constitutionally adequate medical care while housed at the Elkhart 

Jail in violation of the Fourteenth Amendment. (Id.) On October 15, 2018, MayweatherBrown filed a motion for summary judgment asserting he is entitled to judgment as a

matter of law on his claims. (ECF 200.) On December 4, 2018, the Defendants responded 

by filing cross-motions for summary judgment (ECF 210; 213) asserting there are no 

genuine issues of material fact to support Mayweather-Brown’s claims. The crossmotions for summary judgment were accompanied by notices informing MayweatherBrown of the motions as required by N.D. Ind. L.R. 56-1(f). (ECF 215; 216.) On February 
2

19, 2019, Mayweather-Brown filed a reply (ECF 231, 232-1) and, on April 15, 2019, he 

filed a sur-reply. (ECF 258.) On August 2, 2019, Dr. Mathew, Yohn, and Yoder filed a 

response to Mayweather-Brown’s sur-reply. (ECF 286.) 

FACTS1

Mayweather-Brown was a pretrial detainee at the Elkhart Jail from March 20, 

2014 to June 6, 2014, when he was transferred to the Indiana Department of Correction

(“IDOC”). (ECF 212-2 at ¶ 5, 212-2 at 6-8, 42-55, 212-4 at 27:15-20.) He returned to the 

Elkhart Jail on May 22, 2015 and remained there until January 21, 2016, when he was 

again transferred to the IDOC. (Id.)

Mayweather-Brown has sued Lieutenant Bigler, Captain Perry, Dr. Mathew, Mr. 

Yoder and Ms. Yohn. Bigler was employed by the Elkhart County Sheriff’s Department 

(“Sheriff’s Department”) as a Sergeant and Lieutenant in the Corrections Division from 

August 2003 through October 2015. (ECF 212-1 at ¶¶ 2, 3.) Perry was employed by the 

Sheriff’s Department as the Captain of the Corrections Division throughout the time 

period relevant to this case. (ECF 212-2 at ¶¶ 2, 3.) 

Dr. Mathew is a psychiatrist who works for Correct Care Solutions (“CCS”), a 

private company that contracted with the Sheriff’s Department to provide healthcare to 

inmates at the Elkhart Jail. (ECF 212-5 at ¶ 3.) He is responsible for providing mental 

health services by diagnosing inmates who have behavioral and psychiatric disorders, 

prescribing and managing psychiatric medication for inmates, and seeing inmates as 

 

1 The facts are largely uncontested, and the court has borrowed heavily from the Defendants’ 

Statement of Material Facts. (ECF 212.)
3

needed for acute psychiatric issues. (Id. at ¶ 4.) Dr. Mathew creates treatment plans for 

inmates and advises mental health staff on how best to treat inmates; however, he does 

not take an active role in monitoring the day-to-day mental healthcare of inmates. (Id.)

Yoder is a licensed clinical social worker and was employed by CCS at the 

Elkhart Jail during the relevant period. (ECF 212-7 at ¶¶ 2, 3.) He provided mental 

health counseling services by assisting inmates who had acute mental health issues and

worked with doctors who developed treatment plans for inmates. (Id. at ¶ 4.) Yoder did 

not diagnose inmates, prescribe medication, or dictate treatment plans for inmates. (Id.) 

He also did not direct the actions of correctional officers and only carried out the 

treatment plans established by jail physicians. (Id.)

Yohn, a registered nurse, was employed as a Health Services Administrator by 

CCS at the Elkhart Jail during the relevant period. (ECF 212-6 at ¶ 3.) Her position was 

primarily administrative in nature because she served as the liaison between the Elkhart 

Jail Administration and the medical department. (Id. at ¶ 4.) Yohn’s duties entailed 

ordering medical supplies, hiring medical staff, maintaining nursing staff schedules, 

responding to inmate grievances regarding medical issues, and handling human 

resource issues for the medical staff. Id. She did not have the authority to prescribe 

medications, recommend treatments, or refer patients to specialists. (Id.)

March 20, 2014 to June 6, 2014

On the morning of March 20, 2014, Mayweather-Brown was booked into the 

Elkhart Jail. (ECF 212-3 at 55.) Immediately upon his intake, he was referred to mental 

health staff because he had made suicide threats to the police officers who had 
4

transported him to jail. (Id. at 53-54.) However, once Mayweather-Brown arrived at the 

Elkhart Jail, he told the jail’s staff that he was not going to harm himself. (Id. at 55.) Dr. 

John Foster, a jail doctor, prescribed Remeron (antidepressant medication), Zyprexa

(antipsychotic medication), Haldol (antipsychotic medication), and Ativan (anxiety 

medication) for his symptoms. (Id. at 56.) At that time, Mayweather-Brown did not have 

a comprehensive intake screening because he was combative. (Id. at 57, 59.) Despite 

telling medical staff that he did not intend to harm himself, he told one staff member 

that, “If I go in a padded cell I will cause problems for everyone.” (Id. at 61.)

At 2:00 p.m. on March 20, 2014, Mayweather-Brown became upset about his legal 

charges and was taken to a classroom to walk around and calm down. (ECF 212-3 at 73.)

Twenty minutes later at 2:21 p.m., Dr. Foster was alerted that Mayweather-Brown had 

attempted to hang himself with a blanket and was complaining of not being able to feel 

his body from his neck down. (Id. at 76-77.) Jail officers, however, were able to see there 

was slack in the blanket around his neck and he was moving his head on his own. (Id.)

Mayweather-Brown was then transported to the medical unit on a backboard where Dr. 

Foster observed that he was able to move his arms. (Id.) Dr. Foster examined him and 

noted that all of his reflexes were intact, and he could move all of his appendages. Id.

He complained that he had neck pain, but while he was waiting for a neck x-ray, 

admitted that there was nothing wrong with his neck.2 (Id. at 70-71, 76-77.)

 

2 At some point after Mayweather-Brown attempted to commit suicide, he was asked to remove 

his clothes but was reluctant to do so. (ECF 238 at 47.) Several jail officers forced Mayweather-Brown to 

the floor where they removed his clothing. (Id.) As a result of the incident, one jail officer was demoted 

from his supervisory position. (ECF 280-1 at 1-8.) However, that jail officer is not a defendant in this case.
5

At 3:30 p.m. on March 20, 2014, Mayweather-Brown refused his medication, 

stating “Don’t give me a f****** shot. That s*** better be court ordered. I ain’t taking 

s***.” (ECF 212-3 at 68.) He was extremely agitated and aggressive, and stated that he 

would “get every worker here.” (Id.) About two hours later at t 5:45 p.m., another jail 

doctor, Dr. Robbins ordered an Ativan injection. (Id. at 64-65.) However, at 8:10 p.m., he 

refused his medications and would not sign a refusal of treatment form. (Id. at 64.) At 

around 9:30 p.m., he tied a wire around his neck and threatened suicide. (Id.) However, 

he agreed to turn over the wire to medical staff upon receiving several cups of water. 

(Id.)

The next day, on March 21, 2014, Mayweather-Brown refused his medication and 

would not sign the refusal of treatment form. (ECF 212-3 at 81-82.) At 9:40 a.m. that day, 

he was evaluated by mental health staff. (Id. at 96.) They noted that he had attempted to 

kill himself three times in the past twenty-four hours, verbalized intentions to drown 

himself, threatened to bang his head on the floor until he injured himself, and injured 

an officer by punching and biting him. (Id.) Mayweather-Brown also refused his last 

two meals, dismantled the intercom system in his room, and tied the wires from the 

intercom system around his neck. (Id.)

At 9:47 a.m. on March 21, 2014, Mayweather-Brown refused to give his blanket 

and sleeping mat to jail officers. (ECF 212-3 at 92.) He was verbally abusive and 

threatened the officers. Id. Jail officers had to employ pepper spray to gain control of 

Mayweather-Brown and he was placed in a restraint chair. (Id.) Once restrained, he 
6

stated that, after he was released from the chair, he was going to “bang [his] head on the 

floor until [he had] a concussion.” (Id.) He then threatened to “kill every officer.” (Id.)

At about 12:00 p.m., while he was still being restrained, Mayweather-Brown

threatened to drown himself by putting his head in the toilet. (ECF 212-3 at 88, 93, 95.)

He continued to yell, threaten himself and threaten staff, and refused to take his 

medications. (Id.) However, he later agreed to take Ativan but refused it when it was 

provided to him. (Id.) Later that evening, Mayweather-Brown declared that he was “on 

a water strike” and demanded to be hooked up to an IV. (Id. at 94.) He started drinking 

water and Boost, a nutritional meal shake, the next morning. (Id.)

Yoder, a licensed clinical social worker at the jail, initially became aware of Mr. 

Mayweather-Brown on March 21, 2014, during a meeting with correctional and medical 

staff. (ECF 212-7 at ¶ 5.) Yoder subsequently consulted with Dr. Mathew, a psychiatrist 

at Oaklawn Hospital, to request that Mayweather-Brown be admitted for inpatient 

psychiatric care. (Id. ¶ 6.) Dr. Mathew refused to admit him because Oaklawn was not 

equipped to manage his violent behavior. (Id.)

On March 22, 2014, Mayweather-Brown again refused to take his medications. 

(ECF 212-3 at 98-102.) At 12:36 p.m., Nurse Williams noted that jail staff had used 

pepper spray on Mayweather-Brown twice in one hour and he refused to allow the 

nurses to clean and bandage scratches on his arms. (Id. at 106.) Around 1:49 p.m., Mr. 

Mayweather-Brown remained verbally aggressive with staff and continued to request 

medical help but would then refuse help when it was offered. (Id.) Around 2:03 p.m., he

again asked for medical help. (Id. at 105-06.) When medical staff asked what he needed, 
7

he replied “I don’t know, I just need help and you’re not helping.” (Id.) MayweatherBrown continued to be verbally aggressive to medical staff. (Id.)

In the evening of March 22, 2014, Mayweather-Brown asked to be put in the 

restraint chair and stated he would harm himself if he were released from the chair. 

(ECF 212-3 at 105.) He refused medication, water, Boost, and a check of his vital signs. 

(Id.) Mayweather-Brown was released from the restraint chair later that evening and 

was given water and food. (Id.) Because he complained of nausea, the jail doctor 

ordered anti-nausea medication. (Id. at 104.)

The next day, on March 23, 2014, Mayweather-Brown refused his meals and 

medications, except for his anti-nausea medication. (ECF 212-3 at 108, 113.) At about 

7:50 a.m., Mayweather-Brown complained that he could not breathe. (Id. at 114.) He was 

examined and it was noted that his oxygen saturation was at ninety-eight percent. (Id.)

However, he refused his inhaler. (Id.) At 8:24 a.m., Mr. Mayweather-Brown complained 

of vomiting and told the nurses that he needed IV fluids and potassium. (Id.) He stated 

“[c]all the doctor and tell him that s***. I’m [] dehydrated and [will] sue you d******

nurses and doctors.” (Id. at 114-15.) Around noon, he was given a meal tray, and he ate 

his lunch. (Id. at 115.)

On March 24, 2014, Mayweather-Brown refused his Ativan and Boost. (ECF 212-3

at 116-117.) At 8:30 a.m., he was observed sitting in his cell and did not exhibit signs of 

negative behavior. (Id. at 123-124.) Yoder followed up with him at 2:00 p.m. and noted 

that he remained agitated and hostile, and that he made several threats toward staff. (Id.

at 121.) Mayweather-Brown requested that he be released from suicide watch, but 
8

Yoder noted that his behavior did not warrant being released from suicide watch. (Id.)

Yoder met with Mayweather-Brown’s family to discuss the option of bonding him out

of jail. (ECF 212-7 at ¶7.) However, they had not yet decided if they wanted to take that 

action and were concerned that if he were released, he would be brought back to jail

immediately. (Id.)

At about 3:00 p.m. that day, Mayweather-Brown put his face in the toilet. (ECF 

212-3 at 123.) His examination showed he had normal vital signs, but he refused to 

speak with the nursing staff. Id. Later that afternoon, he was placed in the restraint chair 

because he was picking paint chips off his cell wall. (Id.) He was released from the 

restraint chair by 8:20 p.m. and refused his evening medications. (Id.)

On March 25, 2014, Mayweather-Brown refused to take his morning medications 

because he felt that staff were “just trying to control [his] emotions.” (ECF 212-3 at 129, 

148.) At 9:40 a.m., he was observed putting a towel around his neck and, subsequently, 

he was placed in the restraint chair. (Id. at 132-34.) After being restrained, he began 

yelling at officers. (Id. at 139.) He was offered the chance to return to his cell but stated 

that, if he was placed back in his cell, he would get paint chips off the wall to slit his 

throat. (Id. at 148.) At around 11:15 a.m., Yoder met with Mayweather-Brown and 

offered to take him out of the restraint chair and place him back in his cell. (Id. at 144.)

However, he requested that he remain in the restraint chair, stating “no, I hate it in 

there, I like it out here, and I can watch everything going on.” (Id.) At 6:10 p.m.,

Mayweather-Brown was released from the restraint chair and was given a suicide 
9

smock and blanket. (Id. pg. 149.) However, because he refused to enter his cell without a 

sleeping mat, he was placed back in the restraint chair. (Id.)

The next day, on March 26, 2014, Mayweather-Brown refused Boost and his 

Ativan. (ECF 212-3 at 151.) Yoder followed-up with him and noted that he became 

agitated when he was reminded of his many suicidal and self-harm gestures. (Id. pg. 

154.) Yoder explained that he would need to have stable behavior for three days before 

he could be considered for a lower level of suicide watch. (Id.) This news agitated 

Mayweather-Brown and he began at Yoder. (Id.) In fact, he told Yoder repeatedly that 

jail staff was “depriving him of his rights.” (Id.)

On March 27, 2014, Mayweather-Brown refused his Boost and Ativan. (ECF 212-3

at 159-60.) Yoder followed-up with him and noted that his behavior had improved 

somewhat. (Id. at 162.) Mayweather-Brown requested that he be downgraded to a levelthree suicide watch (a less intensive level of suicide observation, but Yoder told him 

that his suicide level could not be lowered that day. (Id.) His behavior then escalated,

and he began swearing at Yoder, who noted that “unless [he] give Mr. MayweatherBrown exactly what he wants he will be certain everyone knows he is pissed about the 

alternatives.” (Id.) Yoder also noted that jail staff had raised concerns that MayweatherBrown was adversely impacting them. (Id.) However, on March 27, 2014, there were 

reports of Mayweather-Brown attempting to harm himself. (Id. at 165.)

On March 28, 2014, Dr. Robbins placed Mayweather-Brown on a level-three

suicide watch. (ECF 212-3 at 171.) Later in the day, however, when he learned that his 

family would not post bond to release him from jail, his behavior escalated. (Id.) He 
10

began screaming “I’m going to finish what I started, this is going to be a long 

weekend.” (Id.) Yoder reported that his anger was completely unmanageable. (Id.)

On March 29, 2014, Mayweather-Brown reported that he was throwing up and 

needed medical assistance. (ECF 212-3 at 180.) He was verbally aggressive and refused 

the liquid diet ordered by the medical provider. (Id.) A nurse examined him and noted 

there were no signs of vomit in his cell, and he did not appear to be malnourished or 

dehydrated. (Id.) The nurse explained to Mayweather-Brown that emotional upset can 

cause stomach upset, and he responded by saying “you don’t know nothing b  move 

out of the way.” (Id.)

At 7:50 p.m. on March 29, 2014, Mayweather-Brown was observed talking with 

the chaplain but did not exhibit negative behaviors. (ECF 212-3 at 182.) At 9:30 p.m., 

medical staff was notified that he was ripping his sleeping mat cover apart and telling 

officers that he was going to “slit his f** **** wrist.” (Id.) Mayweather-Brown was put in 

the restraint chair briefly, and then released back to his cell when he agreed to take his 

Ativan. (Id.)

In March 2014, Mayweather-Brown continued to display aggressive behavior. 

For example, on March 30, 2014, he remained on level-two suicide watch. (ECF 212-3 at

184.) The next day, on March 31, 2014, an Elkhart Superior Court Judge authorized jail 

doctors to administer medication over his objection due to his extreme behavior. (Id. at

185.) On that day, he also made several gestures to harm himself by tying things around 

his neck. (Id. at 187.)
11

On April 1, 2014, Mayweather-Brown refused to take his medications. (ECF 212-3

at 199.) Mental health staff followed-up with him and noted that he blamed the jail 

officers’ actions for his outbursts and negative behavior. (Id. at 201.) For example, he 

told officers that he would tear up a padded cell if he were put in one and, after officers 

put him in a padded cell, he destroyed it. (Id.) Mayweather-Brown felt that this was the 

jail officers’ fault. (Id.)

On April 2, 2014, Mayweather-Brown refused his morning medications. (ECF 

212-3 at 204.) He was released from suicide precautions and housed in the K-pod. (Id. at 

207.) He expressed anxiety about being taken off of suicide watch status but remained 

hopeful that his sister would bond him out of jail the next day. (Id.) Furthermore, in 

early April 2014, Mayweather-Brown also refused to take his Zyprexa and Remeron

medications. (Id. at 222, 225.)

On April 10, 2014, at about 3:30 p.m., Mayweather-Brown reported that he 

ingested multiple pills and swallowed shampoo. (ECF 212-3 at 233, 236.) Dr. Foster 

examined him and reported that he exhibited this behavior because he could not get in 

contact with his sister. (Id. at 223.) Dr. Foster advised that, even after taking multiple 

Thorazine and Ativan tablets, he was still below the daily maximum dose for these 

medications and they should not cause him any medical problems. (Id. at 235.) At 4:00 

p.m., Mayweather-Brown was in his cell and urinated on himself. (Id. at 236-37.) He

urinated on himself again around 4:40 p.m., 5:15 p.m., and 5:50 p.m. (Id.)

On April 11, 2014, Mayweather-Brown refused his morning medications. (ECF 

212-3 at 238, 240.) During a mental health assessment that day, he told staff that he 
12

“made the whole story up—I didn’t intend to kill myself.” (Id. at 242.) Dr. Robbins

noted that he made up his attempted overdose and expressed his desire to be taken off 

of suicide watch. (Id. at 244.) At 10:00 p.m., he refused his Zyprexa, saying “I don’t want 

the Zyprexa but I want the others. I don’t know why I don’t want it, I just don’t want 

it.” (Id. at 247.) He also threatened jail staff, saying “I’m getting really sick of this, I got a 

big lawsuit coming with the news and everything coming, lots of people are going to 

lose their jobs.” (Id.)

The next day, on April 12, 2014, Mayweather-Brown once again refused his 

morning medications. (ECF 212-3 at 248.) The next day, on April 13, 2014, he remained 

on a level-two suicide watch. (Id. at 250-51.) He refused his antipsychotic medication 

because he believed that the “jail was trying to find him incompetent” and he wanted 

“to show everyone that he does not need the medication.” (Id.) Mayweather-Brown did 

not engage in disruptive behavior and requested Ativan at 11:15 p.m. for agitation. (Id.

at 252.)

On April 14, 2014, Mayweather-Brown stated he would not take Zyprexa because 

he was no longer taking antipsychotic medication. (ECF 212-3 at 253.) At 7:30 a.m., he 

was observed by mental health staff resting in his cell with his sleeping mat and 

blanket. (Id. at 257.) He had a discussion with mental health staff about his mental 

health diagnosis and the criteria needed to be considered for a state mental hospital. (Id.

at 256.) Around 2:00 p.m., Mayweather-Brown became upset when his medication was 

crushed into a cup without him watching. (Id. at 254.) He cursed, yelled at, and 

threatened the nursing staff. (Id.) The nursing staff told Mayweather-Brown that they 
13

would crush the medication with him watching, and they offered to do that 

immediately, but he refused his medications. (Id.)

On April 15, 2014, Mayweather-Brown refused to take his morning medications. 

(ECF 212-3 at 258.) Yoder followed-up with him on suicide watch and noted that he had 

voiced no suicidal ideations. (Id. at 261.) He was antagonistic toward nursing staff. (Id.) 

Yoder noted that he had been seen by Dr. Robbins, who opined that he was controlling 

and his attention seeking behavior was consistent with anti-social personality disorder. 

(Id.) At 10:00 a.m., he was cleared from suicide watch to return to general population. 

(Id. at 264.)

Also, on April 15, 2014, Mayweather-Brown wrote a letter to the Elkhart County 

Sheriff, Bigler, and Perry. (ECF 212-3 at 259.) In his letter, he explained that he had been 

intentionally provoked by being placed in situations “knowing full well where the 

situations have led to in the past.” (Id.) He further explained that he had a welldocumented history of post-traumatic stress disorder (P.T.S.D.), which had never been 

documented by mental health staff, and claimed the jail staff was mentally abusing him 

by placing him in situations he did not like and “triggering his P.T.S.D.” (Id.)

The next day, on April 16, 2014, Yoder assisted in developing a mental health 

treatment plan for Mayweather-Brown. (ECF 212-3 at 266.) He was diagnosed with 

impulse control disorder and antisocial personality disorder. (Id.) The focus of the 

treatment plan was to manage his agitation and suicidal gestures. (Id.)

On April 17, 2014, Mayweather-Brown refused to take his morning medications. 

(ECF 212-3 at 268.) At 7:00 a.m., medical staff was called to his cell because he reported 
14

being short of breath. (Id.) When a nurse arrived at his cell, Mayweather-Brown refused 

to do a pulmonary function test, stating “I don’t need to do all that cause it’s going to 

throw me into an attack....see you nurses all don’t know what the h*** you [are] doing.” 

(Id.) The nurse who examined him noted that his oxygen saturation was ninety-six 

percent and he was neither whistling nor wheezing, and his breathing was even and 

unlabored. (Id.) When the nurse gave Mayweather-Brown his inhaler, he did not take 

puffs from it but instead simply gave it back to her and walked upstairs. (Id.)

On April 18, 2014, Yoder met with Mayweather-Brown and noted that he 

continued to request changes in his medication. (ECF 212-3 at 272.) He denied that he 

was psychotic and refused to take antipsychotic medication but requested Geodon

(antipsychotic medication). (Id.) He also expressed anxiety over his pending court 

hearings. (Id. at 273.)

On April 24, 2014, Mayweather-Brown was scheduled for a chronic care asthma 

visit with Dr. Foster. (ECF 212-3 at 280.) Dr. Foster noted that he initially refused to go 

to his appointment but arrived later in the day to see him. (Id.) During the appointment, 

he threatened physical violence if he could not immediately leave the appointment and 

then left with another group of inmates and went back to his unit. (Id. at 279-80, 283.)

Dr. Foster noted that he manipulated medical staff by refusing to use his Albuterol 

inhaler and then would ask to use it immediately after nurses left his unit. (Id. at 280.)

He also noted that Mayweather-Brown’s asthma was mild and could be controlled with 

medication, but he was non-compliant and deceptive in saying that nurses did not bring 

him his medication. (Id. at 282.)
15

Five days later, on April 29, 2014, Mayweather-Brown once again refused to take 

his morning medication. (ECF 212-3 at 286.) That day, he also refused his evening 

medications stating: “I plan to be in the chair all night so I don’t need them.” (Id. at 287.)

At 5:45 p.m., he asked to be seen by medical staff. (Id. at 299.) However, after medical 

staff arrived, he refused to identify his medical issue and refused to speak with the 

nurse because he “doesn’t like” the nurse who was available to see him. (Id.) The 

medical staff left after Mayweather-Brown refused care, and he became aggressive and 

combative with jail officers and was placed in the restraint chair. (Id. at 299, 301.) The 

medical staff then returned thirty minutes later because he stated he was having an 

asthma attack. (Id. at 299.) However, once the medical staff arrived, they observed

Mayweather-Brown was not in distress because he was yelling and cursing at jail 

officers. (Id.) He was administered his asthma inhaler. (Id.)

After being placed in the restraint chair, Mayweather-Brown refused to have 

restraint chair assessments at 5:45 p.m., 6:00 p.m., 6:05 p.m. 6:30, p.m., 6:40 p.m., 7:00 

p.m., 7:30 p.m., 7:37 p.m., and 8:00 p.m. (ECF 212-3 at 288-96.) At 6:30 p.m., he stated

“I’ll sit in this chair all night, this doesn’t bother me, I’m fine.” (Id. at 293, 300.) At 7:30 

p.m., he was heard yelling at officers, stating “I’m suing you personally Cole, I’m 

coming after you and your job.” (Id. at 300.) By 7:37 p.m., he told medical staff to call the 

doctor and tell them that an officer was “personally messing with [his] P.T.S.D. and 

whatever happens is not [his] problem.” (Id.) He was taken out of the restraint chair at 

9:18 p.m. (Id. at 301.)
16

The next day, on April 30, 2014, Mayweather-Brown refused his morning asthma 

medications. (ECF 212-3 at 303.) At 2:30 p.m. that day, mental health staff attempted to 

talk with him about his behavior that led to his placement on suicide watch. (Id. at 311.)

He admitted to threats of self-harm, said he was not suicidal, and did not need to be on 

suicide watch. (Id.) He blamed his threats of self-harm on jail officers because they 

triggered his P.T.S.D. (Id.) Mayweather-Brown showed the mental health staff worker a 

plastic spoon and said he was going to harm himself. (Id.) He then proceeded to make 

cutting actions at his wrist with the spoon. (Id.)

At 2:50 p.m. that day, Mayweather-Brown requested that he be placed in the 

restraint chair. (ECF 212-3 at 310.) He refused to turn over his plastic spoon to jail 

officers. (Id.) At 3:10 p.m., he yelled to Nurse Emily Emery that he was going on a 

hunger and water strike. (Id. at 309.) Twenty minutes later, Katherine Brown, a mental 

healthcare worker, spoke with Mayweather-Brown, who was yelling and wanted to 

know why he was on suicide precautions. (Id. at 311.) Brown responded that he was on 

suicide precautions due to the threats of self-harm that he had made the previous day. 

(Id.) This caused him to escalate his behavior and he threatened to bang his head against 

a railing, saying “what are you going to do to stop me?” (Id.) He also stated that he was 

being discriminated against. (Id.) At 4:00 p.m., Mayweather-Brown refused to let jail

officers restrain his right hand in the restraint chair. (Id. at 310.) He then became violent 

with custody officers, made verbal threats, and began thrashing his body around in the 

restraint chair. (Id.) He refused medical checks every twenty minutes while in the 

restraint chair. (Id.) At 6:36 p.m., he requested that medical staff check his vital signs 
17

and clean a cut on his right shoulder. (Id. at 312-13.) Medical staff attended to his needs 

and noted he was eating and drinking water so his hunger and water strike had ended. 

(Id.)

On April 30, 2014, Mayweather-Brown underwent a self-harm initial assessment. 

(ECF 212-3 at 314.) Mental health staff noted he made suicidal statements to jail officers 

after he became upset that he could not make copies. (Id.) He informed Mary Marcus, a 

mental healthcare worker, that he was not suicidal and denied saying anything related 

to self-harm. (Id. at 315.)

The next day, on May 1, 2014, a 11:30 a.m., jail officers observed MayweatherBrown attempting to harm himself. (ECF 212-3 at 323.) They tried to place him in the 

restraint chair but he became combative and spit at them. (Id.) He then grabbed the 

officers’ hands and tried to twist and break their fingers. (Id.) Mayweather-Brown hit 

the officers with his knees and attempted to use his head as a weapon. (Id.) After being 

placed in the restraint chair, he threated officers, saying “I’m going to f*** you up! Stop 

touching me, I’ll kill you! You don’t have a soul.” (Id. at 339.)

That same day while he was still in the restraint chair, Dr. Foster examined 

Mayweather-Brown to access his chronic asthma. (ECF 212-3 at 329-31.) He noted that

Mayweather-Brown’s biggest hurdle to his health was himself and he would be 

healthier if he were compliant with his medications. (Id.) Brown also followed up with 

him and noted the incident began when he was given a normal sack lunch instead of a 
18

special lunch.3 (Id. at 336-37.) Mayweather-Brown reported that he is unable to control 

himself when his anger is triggered. (Id.) He requested that medical staff, mental health 

staff, and jail officials develop treatment plan to respond to his behavior. (Id.)

On May 2, 2014, Mayweather-Brown was given his medication at which time he 

informed the medical staff that he would not take the medication and would not give it 

back. (ECF 212-3 at 341, 345.) He was also examined for complaints of a strained neck 

and he was given an ice pack. (Id. at 342-44.) At 5:25 p.m., Mayweather-Brown refused 

to return the ice pack and stated that “the officer over there pissed me off so I’m not 

giving this back and [I am] going to eat it.” (Id. at 349.) At 8:10 p.m., while a nurse 

examined him, he stated to her “Nurse, look I am cutting myself. Nurse, I am harming 

myself aren’t you going to do anything?” (Id. at 349.) The nursing staff was advised that 

they should not enter his cell because of his hostility toward them, which increased his 

anger. (Id.)

At 9:00 p.m. that same day, a nurse observed Mayweather-Brown in his cell with 

a small metal object that he was using to make small lacerations to his left arm. (ECF 

212-3 at 345-46.) He requested that the nurse clean and bandage his cuts, but jail staff 

advised the nurse not to enter the cell as long as he had the piece of metal. (Id.) He 

refused to give jail officers the piece of metal and appeared agitated and combative. (Id.)

Several hours later at 11:00 p.m., a nurse observed Mayweather-Brown yelling at a jail 

officer stating, “I don’t like your face Goodwin, you make me agitated.” (Id. at 345.) The 

 

3 Mayweather-Brown was given a special lunch the day before, in response to his threat of a 

hunger strike. (ECF 212-3 at 336-37.)
19

nurse gave him Tylenol and allergy medicine in a cup, but he took the cup, dumped the 

water out, and kept the medication. (Id.) He stated, “I’m not taking these meds and I’m 

not giving the cup back, you guys can come in and get it.” (Id.) However, jail officers 

did not enter the cell to retrieve the medication or the cup. (Id.)

On May 3, 2014, Dr. Foster discontinued Mayweather-Brown’s Tylenol and 

allergy medication because he refused to take the medications the day before. (ECF 212-

3 at 345, 351.) At 1:25 a.m., a nurse was called to examine Mayweather-Brown. (Id. at 

353.) He reported that he had been banging his head on the wall and, as a result, had a 

headache and experienced blackouts. (Id.) The nurse explained she could not enter his 

cell and provide care until he calmed down. (Id.) At 2:21 a.m., Mayweather-Brown

requested Ativan and Geodon and took these medications. (Id.) He also stuck his left 

arm out of the slot in his door and allowed a nurse to clean and bandage ten superficial 

cuts on his arm. (Id.) At 4:12 a.m., jail officers informed the nursing staff that he had 

refused his breakfast and announced he was going on a hunger strike. (Id.) At 6:20 a.m., 

Mayweather-Brown refused his dinner and said he would not drink any water. (Id.)

However, he later drank 120 milliliters of water. (Id.)

At 2:10 p.m. on the same day, Mayweather-Brown ate ten percent of his lunch 

and asked to speak with mental health staff regarding his hunger strike. (ECF 212-3 at 

357-58.) The nursing staff observed him making verbal threats against the medical and 

jail staff. (Id.) At 4:45 p.m., he consumed two Boost supplements. (Id.)

On May 5, 2014, Mayweather-Brown refused to take Geodon. (ECF 212-3 at 359.)

Between 1:10 p.m. and 2:30 p.m., he became very upset that he was being given 
20

nutraloaf4 instead of normal meals and stated he would remain on a hunger strike until 

he got regular food. (Id. at 360, 365.) He was then given two Boost supplements, which 

he drank. (Id. at 360.) Mayweather-Brown still had the metal object that he used to cut 

his arm on May 2, 2014. (Id.) He was told that he would not be moved to level-three

suicide watch until he surrendered the piece of metal. (Id.) At 3:40 p.m., he was moved 

from level-two suicide watch to a level-three suicide watch because he remained calm 

all day. (Id. at 360, 363.)

On May 6, 2014, Mayweather-Brown requested that he return to general 

population. (ECF 212-3 at 367.) He acknowledged that he allowed people to get under 

his skin and then acted out to prove them right. (Id.)

On May 8, 2014, at 6:00 p.m., Mayweather-Brown requested his asthma inhalers. 

(ECF 212-3 at 372.) The nurse told him that he no longer had an “as needed” order and 

would have to wait until he had a medical pass. (Id.) At 6:50 p.m., Mayweather-Brown’s 

cellmate alerted medical staff that he was unresponsive. (Id.) Nursing staff arrived and 

observed him sitting on the floor with no signs of respiratory distress. (Id.) He refused 

to answer any questions until he received his inhalers. (Id.) The nurse allowed him to 

use his inhaler, even though he was not showing any signs of respiratory distress. (Id.)

Mayweather-Brown put in a request for health care, complaining of extreme neck pain 

due to the jail officers’ use of force. (Id. at 373.) His neck was examined; however, there 

was no swelling. (Id.) He was prescribed Tylenol for muscle aches. (Id.)

 

4 Nutraloaf is a food like meatloaf in texture that is served to inmates who have misbehaved that 

does not require the use of utensils.
21

On May 9, 2014, Mayweather-Brown was placed on suicide watch because he 

made suicidal statements, which he later denied. (ECF 212-3 at 375.) After being placed 

on suicide watch, he engaged in a series of self-injury behaviors. (Id.)

On May 10, 2014, Mayweather-Brown complained that he had a torn ligament in 

his neck and stated he should not have to be triaged because he was allegedly injured 

by jail officers’ use of force. (ECF 212-3 at 378.) He was given Tylenol for his neck pain

and had no behavioral issues on May 10, 2014. (Id. at 381-82.)

On May 11, 2014, Mayweather-Brown was compliant with his medications

except for the Geodon. (ECF 212-3 at 383.) He stated he had chronic migraines, which he 

had never complained about before, and asked for medication. (Id.)

The next day, on May 12, 2014, someone placed a call from the intercom system 

in Mayweather-Brown’s cell to inform prison staff that someone was thinking of 

suicide. (ECF 212-3 at 385.) Both Mayweather-Brown and his cellmate denied making 

the call and the inmates were placed on suicide watch. (Id.) Mayweather-Brown was

later observed sitting on his bunk and singing. (Id. at 387.)

On May 13, 2014, Mayweather-Brown told mental health staff that he was highly 

agitated because he felt things at the jail should be done differently. (ECF 212-3 at 388.)

He was loud and demanding at that time. (Id.)

Two days later, on May 15, 2014, Mayweather-Brown refused to take Geodon. 

(ECF 212-3 at 393.) He was later placed on suicide watch at his request. (Id. at 394.) He 

stated he was angry and did not want to his behavior to escalate. (Id.) He also indicated 

that he did not want to be housed in the K-42 pod (mental health unit) any longer. (Id.)
22

On May 16, 2014, Mr. Mayweather-Brown told Mr. Yoder that he did not have 

any suicidal ideation, and he requested to be on suicide watch so that he could clear his 

head. (ECF 212-3 at 397.) Mr. Mayweather-Brown said that he felt too confined in the K42 pod (the mental health unit) and requested placement in general population. (Id.)

At 1:30 p.m. on May 17, 2014, Mayweather-Brown became agitated and verbally 

threatened others. (ECF 212-3 at 401-02.) He stated that he “is suing all of medical and 

none of you mother******* will have anything left when I’m done with ya.” (Id.) He then 

began throwing paper, tubes of toothpaste, and other items through the tray slot in his 

door. (Id.) Mayweather-Brown also began squirting water from the toilet using a glove 

and was aiming at jail and medical staff, and electronic equipment. (Id.) He requested

Ativan and after taking it, he was calm and laughing with other inmates. (Id.)

The next day, on May 18, 2014 at 8:10 a.m., Mayweather-Brown was seen 

sleeping in his cell with no behavioral issues. (ECF 212-3 at 413-14.) At 11:00 a.m., he 

began flooding his cell and yelling “I will hit my head against this wall until I’m put in 

the chair!” (Id.) He initially refused a vital sign check that morning but allowed the 

medical staff to take his vital signs at 11:55 a.m. (Id.) He drank thirty-two ounces of 

water at 11:55 a.m., and eight ounces of water at 12:25 p.m. (Id.) Mayweather-Brown

then yelled “I am going to make sure to stay in this chair until first shift! Ya’ll wanna 

learn how to do what I do? This video will be on YouTube, take a lesson from me. I can 

tear this place down! I already know how I’m gonna get outta this chair. Now I’m 

hydrated, b******! It’s on! Cooley, you’re a b .” (Id.) He continued yelling at jail and 

medical staff as well as other inmates and broke a railing while in the restraint chair. 
23

(Id.) At 5:00 p.m., he complained of sudden headaches after being placed in the restraint 

chair earlier in the day. (Id. at 407-09.) Nursing staff provided him with Tylenol. (Id.) He

made a similar complaint around 9:00 p.m. (Id. at 413.)

On May 19, 2014, Yoder followed-up with Mayweather-Brown and noted he had 

been more stable until the last ten days, when he had two separate instances on suicide 

watch. (ECF 212-3 at 415-17.) His behavior had escalated over the last forty-eight hours, 

but he was currently calm and rationale. (Id.) Yoder noted that he saw little desire on 

the part of Mayweather-Brown to change his behavior. (Id. at 415-19.) He assessed 

Mayweather-Brown as being narcissistic, anti-social, and made everyone miserable if he 

did not get what he wanted. (Id.)

The next day, on May 20, 2014, Mayweather-Brown refused to take his morning 

medications. (ECF 212-3 at 423.) At 10:15 a.m., he was briefly placed in the restraint 

chair. (Id. at 424.) After being released to his cell at 10:18 a.m., he ripped his shirt and 

banged his head against the windows. (Id.) Mayweather-Brown also began cutting his 

wrist with a piece of a comb. (Id. at 429.) At 11:00 a.m., Yoder observed him after he was 

placed on suicide watch. (Id. at 426-27.) He noted that Mr. Mayweather-Brown had 

verbalized suicidal ideations to jail officers, and this was his third time on suicide watch 

in two weeks. (Id.) Yoder noted that he was hostile about a multitude of perceived 

injustices and that it was his view that the only way to respond to these injustices was 

to act out. (Id.)

Between 1:00 p.m. and 2:00 p.m. on May 20, 2014, Brown, a mental healthcare 

worker, met with Mayweather-Brown while he was on level-two suicide watch. (ECF 
24

212-3 at 425.) Brown reported that he had been making superficial cuts to his left arm 

using a piece of plaster he picked off his cell wall. (Id.) He believed that he was being 

treated unfairly because he was only allowed to have the safety smock and safety 

blanket in his cell with him. (Id.) However, he admitted that he tore the smock before it 

was taken away from him. (Id.) Mayweather-Brown also threw his lunch tray at the wall 

and urinated on the floor of his cell. (Id. at 425.) He then requested a clean cell and a 

blanket. Id. He was told that he would need to remain calm for a period before jail 

officers would move him to another cell. (Id.) He would also need to refrain from 

harming himself before he would be given a blanket. (Id.) At 2:15 p.m., MayweatherBrown began making superficial cuts to his neck and stated that he wanted to bleed 

everywhere. (Id. at 425, 428-29.) Nursing staff noted he had superficial scratches to his 

neck but none of them were actively bleeding. (Id. at 428.) Three hours later at 5:21 p.m., 

Mayweather-Brown called out for medical staff to clean his wounds, but he would not 

surrender the paint chip to jail officers and continued to scratch himself. (Id. at 432.) He 

was told that he would be treated after he stopped scratching himself. (Id.) At 8:30 p.m., 

a nurse was able to clean and bandage the cuts on his arm. (Id. at 433.)

On May 21, 2014, Mayweather-Brown refused to take his morning medications. 

(ECF 212-3 at. 434.) He spoke with mental health staff and explained that his behavior 

the night before was predicated on the fact that he had not been able to file charges 

against an officer who had injured him while he was being placed in the restraint chair. 

(Id. at 439-41.) At 6:20 p.m., he told a nurse that if he was not triaged, he would stab 

himself in the neck. (Id. at 438.) He was then observed holding a broken plastic spoon in 
25

his hands. (Id.) He stated that he was upset because his neck was sore since he did not 

get a mat to sleep on until 11 p.m. the night before. (Id.) Because he was told that a 

nurse would not be available to triage him immediately, he continued to scream and 

threatened to hurt himself. (Id.) Yoder then advised jail officers to remove the plastic 

spoon from his cell and keep him on level-two suicide watch. (Id.) At 7:30 p.m., he was 

observed holding pieces of ripped blanket that had been tied together. (Id. at 437.) He 

was persuaded to hand over the strings and ripped blanket and admitted he behaved 

this way so that he others would listen to him. (Id.)

The next day, on May 22, 2014, Yoder followed up with Mayweather-Brown on 

suicide watch. (ECF 212-3 at. 445-46.) He reported that he wanted to return to the K-42 

unit because “it’s going to be a long weekend, and I will need my mattress.” (Id. at 446.)

At 5:50 p.m., a nurse applied bandages to his scratched forearm. (Id. at 447.) At 9:30 

p.m., Mayweather-Brown told a nurse that Dr. Robbins was going to clear him from 

suicide watch and return him to the general population. (Id.)

In late May 2014, Mayweather-Brown continued to be treated by jail officials. For 

example, on May 23, 2014, Dr. Robbins met with him and renewed his Geodon

prescription. (ECF 212-3 at 449-50.) Several days later, on May 27, 2014, Yoder met with 

Mayweather-Brown and discussed his anxiety over his sister spending his social 

security checks and asked Yoder to call his sister to find out about the money. (Id. at 

449-50.)

In June 2014, Mayweather-Brown refused medical treatment and was placed on 

suicide watch. For example, on June 4, 2014, after refusing to allow medical staff to treat 
26

him, he signed a refusal of treatment form. (ECF 212-3 at 465.) A day later, on June 5, 

2014, Mayweather-Brown was referred to a medical provider due to his non-compliance 

with his Ativan and Geodon. (Id. at 466.) Next, on June 22, 2014, at 9:00 p.m., he 

announced over the intercom that he wanted to kill himself and was subsequently 

placed on level-two suicide watch. (Id. at 469, 470.)

The next day, on June 23, 2014, Mayweather-Brown refused to take his morning 

medication. (ECF 212-3 at 471.) That morning, he had a conflict with his cellmate about 

who would have time outside of the cell. (Id. at 474.) Mayweather-Brown asked to be 

placed on suicide watch so that he could be moved out of his housing unit. (Id.) He did

not express any threats of self-harm. (Id. at 475.)

On June 24, 2014, Mayweather-Brown once again refused to take his morning 

medication. (ECF 212-3 at 477.) He asked to be taken off of suicide watch but was told 

that he would be kept on suicide watch for another twenty-four hours. (Id. at 479.)

On June 24, 2014, Yoder met with Mayweather-Brown and noted he did not 

exhibit any dangerous behavior and did not verbalize suicidal ideations. (ECF 212-3 at

481.) Yoder planned to transition him to the K-42 pod because he would only be in the 

Elkhart Jail for another week and his behavior could be managed if he were not near the 

inmate with whom he had an issue. (Id. at 481-82.)

On July 1, 2014, Mayweather-Brown left the Elkhart Jail. (ECF 212-3 at 487, 499, 

503.) He returned on July 18, 2014, but he left again on July 21, 2014. (Id.) Between May 

2, 2015 and May 29, 2015, he was in and out of the Elkhart Jail. (Id.)
27

May 29, 2015 to January 21, 2016

After returning to the Elkhart Jail, on May 29, 2015, Mayweather-Brown was 

placed in the restraint chair from 6:30 p.m. to 7:47 p.m. because he had an altercation in 

the housing pods. (ECF 212-3 at 518, 521.) The next day, on May 30, 2015 at 2:40 p.m., he 

was advised jail officers that he was having suicidal thoughts. (Id. at 531.) Yoder was

informed of the situation and recommended that Mayweather-Brown be placed on 

suicide watch. (Id.) At 8:50 p.m., a nurse followed up with him and he stated, “I’m fine, 

I just couldn’t be in seg[regation], I can do this all day but I can’t do seg[regation].” (Id.)

Between June 1, 2015, and June 26, 2015, Mayweather-Brown was periodically in 

and out of the Elkhart Jail. (ECF 212-3 at 541.)

On June 1, 2015, Yoder followed up with Mayweather-Brown on suicide watch 

and reported he made veiled suicide threats after he was sent to segregation for being 

written-up. (ECF 212-3 at 547.) He admitted that he made these threats so that he would 

be housed in a unit where he could think clearly. (Id. at 548, 549.)

On June 4, 2015, Yoder met with Mayweather-Brown while he was on suicide 

watch. (ECF 212-3 at 565.) Yoder noted that he was not dangerous and that he was 

angry over how he was being treated. (Id.)

A week later, on June 11, 2015, Dr. Foster examined Mayweather-Brown. (ECF 

212-3 at 571-74.) Dr. Foster noted that he had been at another facility and had recently 

returned to the Elkhart Jail. (Id. at 571.) He also noted that he would make a nebulizer 

available to treat Mayweather-Brown’s asthma. (Id. at 574.)
28

On June 24, 2015, Mayweather-Brown was once again placed on suicide watch. 

(ECF 212-3 at 594.) Yoder noted that he was agitated by a recent court hearing and by 

the denial of his request to be transferred to minimum security housing. (Id. at 593.)

The next day, on June 25, 2015, Yoder met with Mayweather-Brown on suicide 

watch. (ECF 212-3 at 595-96.) Yoder noted that he made suicide threats because he 

wanted to be placed in minimum security housing. (Id. at 596.) Yoder noted that 

Mayweather-Brown’s statements were primarily manipulative. (Id.)

On June 26, 2015, Yoder followed up with Mayweather-Brown on suicide watch

at which time Mayweather-Brown expressed his irritation over his security placement. 

(ECF 212-3 at 598.) He implied that he would “go off” if things did not go his way and 

he would need the restraint chair. (Id.) Several days later, on June 30, 2015, Dr. Joshua

Mathew5, a psychiatrist, conducted an initial psychiatric evaluation of MayweatherBrown. (ECF 212-3 at 599-601.) He initially noted that Mayweather-Brown had a history 

of extreme attention-seeking behavior, manipulating others by threatening self-harm, 

and uncontrollable behavior. (Id.) Mayweather-Brown told Dr. Mathew that he was 

justified in acting out. (Id. at 599.) Dr. Mathew documented his antisocial personality 

and impulse control disorders. (Id.) He did not assess Mayweather-Brown as having 

bipolar or major mood disorders. (Id. at 601.)

 

5 Dr. Mathew previously worked at Oaklawn Hospital and denied Mayweather-Brown 

admission because of his aggressive behavior. But by June 2015, Dr. Mathew was working at the Elkhart 

Jail and employed by Correct Care Solutions. (ECF 215-5 at ¶¶ 3, 5.)
29

At 7:40 p.m. that same day, Mayweather-Brown told a nurse and jail officers that 

he wanted to hurt himself. (ECF 212-3 at 603.) The nurse asked him to repeat himself

and he screamed at her because he had already stated he would hurt himself and did 

not want to say it again. (Id.) The nurse asked him again if he was going to hurt himself 

and he responded, “take it however you want.” (Id.) Mayweather-Brown then stated,

“you had better get mental health here because they are fixing to see how I can really 

act and by the end of the night I will be in the restraint chair and nobody will be safe 

tonight.” (Id.) Yoder was consulted and recommended that he be placed on level-three

suicide watch. (Id.) Mayweather-Brown responded by stating “the only way you will 

move me is with force.” (Id.)

On July 1, 2015, Mayweather-Brown refused his morning inhaler and Clonidine

(high blood pressure medication). (ECF 212-3 at 609.) At 1:00 a.m., he was agitated and 

yelling that he was suing the jail and medical staff. (Id. at 614.) He stated that he was 

suicidal earlier and should have been moved. (Id.) Jail officers did not move him 

because he attempted to fight with them. (Id.) Mayweather-Brown then proceeded to 

complain about his jail experience and that he planned on suing the Elkhart Jail. (Id.)

Yoder met with Mayweather-Brown at 12:00 p.m. and documented that, on the 

previous day, he made suicidal threats and superficial cuts to his wrists with a spoon. 

(Id. at 610, 613-14.) Yoder noted that Mayweather-Brown acted out when he perceived 

that he was being mistreated. (Id. at 610.) He described in meticulous detail for Yoder 

why he was the victim and stated, “don’t you understand I might say anything if I’m 

pissed off?” (Id. at 612, 614.)
30

On July 2, 2015, Mayweather-Brown was placed in the mental health unit. (ECF 

212-3 at 617.) However, he was unhappy about the placement because he thought he 

deserved to be placed in “minimum security.” (Id.) Yoder noted that he had been only 

marginally compliant with his medication and was typically non-complaint if he was 

angry. (Id.) Yoder advised Mayweather-Brown that to be reconsidered for placement in 

different housing he would need to remain stable for over thirty days. (Id.) He 

responded stating “Gary, you know that will never happen.” (Id.)

Three days later, on July 5, 2015, Mayweather-Brown refused to take his morning 

medication. (ECF 212-3 at 618.) The next day, on July 6, 2015, he refused his Clonidine

(id. at 619), and, on July 7, 2015, he also refused to be triaged for his back pain, (id. at

620).

On July 8, 2015, Mayweather-Brown expressed suicidal ideation because he was 

angry about his housing placement. (ECF 212-3 at 622.) He was placed on level-three

suicide watch and he told Yoder that “When I’m pissed I might say something. I’m not 

going to hurt myself.” (Id. at 624.) The next day, on July 2015, Mayweather-Brown

refused his Clonidine. (Id.)

On July 10, 2015, at 6:00 p.m., while inside his cell, Mayweather-Brown yelled to 

a nurse that he was going to hang himself and then placed a piece of fabric against is 

throat. (ECF 212-3 at 626.) The nurse reported that he was irrational, yelling obscenities, 

and inconsolable. (Id.) Mayweather-Brown assaulted two jail officers and was placed on 

level-three suicide watch. (Id.) At 7:40 p.m., he requested to be seen for back pain. (Id. at 

625.) An examination showed that he had no outward signs or symptoms of pain or 
31

difficulty with movement. (Id.) Dr. Foster did not issue any new orders as MayweatherBrown was already taking Tylenol. (Id.)

On July 12, 2015, Mayweather-Brown was angry because he was given ground 

chicken instead of chicken nuggets, refuse his lunch tray, and asked to be given a new 

tray. (ECF 212-3 at 630.) That day, he also covered the inside of his cell window with 

paper. (Id.)

The next day, on July 13, 2015, Mayweather-Brown made suicidal threats to jail 

officers and remained on suicide watch. (ECF 212-3 at 632.) He told Yoder that he got 

“pissed when he is disrespected and not given what it right.” (Id.). Yoder opined that he 

acted out because he could get more attention and create more conflicts with jail 

officers. (Id.) Yoder documented that he had not seen Mayweather-Brown seriously 

contemplate suicide. (Id.) Then, on July 14, 2015 and July 16, 2015, he again refused to 

take his medication. (Id. at 633-34.)

On July 17, 2015, Yoder followed up with Mayweather-Brown on suicide watch 

and noted there had been less conflict since he was placed in the mental health unit.

(ECF 212-3 at 636.) Yoder opined that Mayweather-Brown was struggling to find things 

to complain about in his unit. (Id.) He requested that he take Clonidine at night because 

it made him drowsy. (Id. at 637.) Dr. Mathew changed the order. (Id.)

Two days later, on July 19, 2015, Mayweather-Brown refused to take his morning 

asthma medication. (ECF 212-3 at 641.) At 9:30 a.m. that day, he stated that he would 

hang himself because his television was not turned on. (Id. at 643.) He was then placed 

on level-three suicide watch. (Id.) Jail officers escorted Mayweather-Brown to the 
32

medical unit where he told the medical staff they were not doing their jobs and he 

threatened to file a lawsuit if they did not start doing their jobs. (Id. at 645.) He then 

became aggressive and jail officers escorted him to the booking unit. (Id.) At 9:50 a.m., 

Mayweather-Brown was placed in the restraint chair. (Id. at 645-46.) Around 9:55 a.m., a 

nurse attempted to check his feet, but he responded “you better not touch me you fat 

f** **** nasty a** b , you try to take my socks and you will have to do a use of force. 

You better not touch me. Quit provoking me.” (Id. at 649.)

By 10:00 a.m. that day, Mayweather-Brown was able to get out of the shoulder 

restraints of the restraint chair and stated, “I told you I’d be out of them in [three]

minutes.” (ECF 212-3 at 649.) He continued yelling and threatening jail officers, but they 

managed to place him back in the shoulder restraints. (Id.) At 10:10 a.m., a nurse 

attempted to take his vital signs at which time he stated, “you better not talk to me, 

you’re not supposed to talk to me, don’t talk to me.” (Id. at 649-50.) By 10:25 a.m., 

Mayweather-Brown demanded another nurse. (Id. at 650.) He was verbally abusive to 

the nurse and told her not to touch him or talk to him. (Id.) At 10:30 a.m., MayweatherBrown continued to be verbally aggressive and called a jail officer a “f** **** idiot.” (Id.)

He next told jail officer officers that he had a right to put his hands on them if he felt

threatened. (Id. at 650.) Mayweather-Brown was removed from the restraint chair and 

mental health staff overheard him say that he was not suicidal and should be cleared 

from suicide watch. (Id. at 648.) At 12:10 p.m., he told jail officers he was not going to 

hurt himself. (Id.) They gave him back his property and a new shirt because he had 

ripped the one, he was wearing. (Id.)
33

On July 20, 2015, Yoder met with Mayweather-Brown on suicide watch and

documented that the previous day’s incident was like other incidents where he 

escalated conflict with jail officers. (ECF 212-3 at 652-53.) Yoder released him from 

suicide watch and placed him in the mental house housing unit. (Id.)

The next day, on July 21, 2015, Yoder stated that Mayweather-Brown’s behavior 

was not indicative of a suicidal tendency but instead was strictly behavioral. (ECF 212-3

at 654.) Yoder noted he took great joy and pride in proving that he could get out of the 

restraint chair stating that “they couldn’t control me in super max and you can’t control 

me either.” (Id.) Yoder also noted Mayweather-Brown’s statement that “I have been 

waiting for you to go after me. I intend to make your lives miserable, and you will have 

to constantly deal with me from here on out.” (Id.) Here, Yoder indicated that he would 

continue to instigate episodes with staff, and he enjoyed the constant attention.” (Id. at

654.)

At 11:10 a.m. on July 22, 2015, Mayweather-Brown was placed in the restraint 

chair because of his aggressive behavior and verbal threats. (ECF 212-3 at 660.) In this 

regard, he stated to one jail officer that “I’ve already got [ten] lawsuits goin’ against 

you.” (Id. at 660.) Mayweather-Brown was offered medical attention every fifteen 

minutes, but he refused it. (Id. at 157, 159, 660). At 1:25 p.m., a nurse offered him water 

and he responded “no, f*** you!” (Id. at 656, 661.) Yoder followed-up with MayweatherBrown on suicide watch and noted that, given his persistent pattern of hostility, Dr. 

Mathew would need to evaluate whether he could be released from suicide watch. (Id.

at 663.)
34

The next day, on July 23, 2015, Mayweather-Brown met with Dr. Mathew and 

Brown. (ECF 212-3 at 667). Mayweather-Brown requested the meeting because he 

wanted a treatment plan that would help him. (Id.) Mayweather-Brown explained that 

he had an anger addiction as a youth and that it worked for him in most settings. (Id.) 

He stated his anger stems from being denied those things for which he has an 

entitlement. (Id.) He described becoming angry when he is ignored and when others are 

not accountable for their actions. (Id.) Mayweather-Brown said he is not suicidal and 

does not want to die. (Id.) He indicated he is a person who is popular and considered to 

be a leader. (Id.) Mayweather-Brown explained that he wanted counseling to “know 

[himself] better. (Id.) He mentioned that a counselor should stand up for what is right 

and take a stand for him when he is right. (Id.) Mayweather-Brown felt he want to 

change the system because he had been treated unfairly and believed a “good 

counselor” would help him do that. (Id.) 

That same day, Dr. Mathew recommended that Mayweather-Brown be housed 

separately—and not with his peers—because of the risk of conflict. (ECF 212-3 at 672.)

He noted that there was no environment that would be completely safe for him and he 

was determined to harm himself and then blame jail officers. (Id.) Dr Mathew did not 

believe that a restraint chair or padded cell would be any safer than his current cell, but 

physical intervention from jail officers increased the risk of harm to Mayweather-Brown 

and the jail staff. (Id.) He recommended a hands-off approach to treatment and noted

Mayweather-Brown’s prognosis was quite poor. (Id.) Dr. Mathew further indicated that 
35

he should have mental health worker visits to be “listened to” during which he can 

discuss his issues. (Id.)

On July 23, 2015, Dr. Mathew also met with Perry to establish a hands-off

approach to manage Mayweather-Brown for his own safety, and for the safety of jail 

officers and healthcare staff. (ECF 212-5 at ¶ 11.) The hands-off approach was not 

created to allow Mayweather-Brown to harm himself. (Id.) To the contrary, Dr. Mathew 

decided on this hands-off approach by analyzing his past behavior and determining 

that his behavior escalated any time medical and jail staff tried to intervene or tried to 

control his environment. (Id.) Dr. Mathew determined that a hands-off approach was 

best because he thought it would be the best way to prevent Mayweather-Brown from 

attempting to harm himself or harming others. (Id.)

At 11:42 a.m. on July 23, 2015, Mayweather-Brown threatened to start “hitting 

his head on the wall.” (ECF 212-3 at 665-66.) Jail officers were able to observe what he 

was doing through the camera in his cell and saw him cover the window of his cell with 

paper and his sleeping mat. (Id.) At 12:30 p.m., he called for medical staff and when 

Nurse Emery responded, he threw a large cup of water on her. (Id. at 664-65.) Nurse 

Emery asked him if he needed medical attention and he responded “No, I don’t. Get 

away from me.” (Id.) At 9:41 p.m., he asked for Tylenol because his back was hurting. 

(Id. at 665.)

On July 24, 2015, Mayweather-Brown was released from suicide watch. (ECF 212-

3 at 685.) Yoder released him based on Dr. Mathew’s new treatment protocol. (Id.) At 

12:15 p.m., he broke the light fixture in his cell, held up a piece of glass to the nurse, and 
36

stated “I’m going to swallow this.” (Id. at 689-90.) The nurse asked Mayweather-Brown

to repeat himself, but he simply smiled and walked away. (Id.) He was then moved to 

another cell for his own safety. (Id.) At 2:00 p.m., Mayweather-Brown refused medical 

treatment for a small cut to his wrist and told the nurse “I don’t want you to treat this, 

just want you to document.” (Id. at 688.) At 3:50 p.m., jail officers were told he had 

swallowed glass, but one officer told the nursing staff to disregard the alleged incident 

because he did not have any glass in his cell. (Id. at 689.)

Two days later, on July 26, 2015, at 12:00 p.m., Mayweather-Brown told Nurse 

Elizabeth Rodriguez “Don’t come near me, I will spray you, I will spray anyone that 

comes near me!” (ECF 212-3 at 692.) Nurse Rodriguez observed him waving a plastic 

container with urine. (Id.) At 1:00 p.m., Nurse Rodriguez witnessed him throw a cup of 

urine at a jail officer. (Id.)

On July 31, 2015, Yoder documented that Mayweather-Brown was permanently 

housed in the booking unit and was permitted to be out of his cell one hour a day, but 

he must be accompanied by jail officer. (ECF 212-3 at 701.) Due to this arrangement, he 

had had fewer episodes of conflict and had not acted out for a week. (Id.)

On August 5, 2015, Mayweather-Brown refused to take Clonidine. (ECF 212-3 at

707.) At 12:30 p.m., he was escorted to the medical unit for a breathing treatment 

because he was wheezing and had shortness of breath. (Id. at 709.) Dr. Foster ordered 

Prednisone (anti-inflammatory medication). (Id.) At 1:10 p.m., a nurse responded to a 

report that Mayweather-Brown cut his arm with glass he found in his cell. (Id. at 714.)

Nurse Emery examined his arm and found four superficial abrasions on his inner right 
37

forearm. (Id.) She cleaned and bandaged his arm and then he stated, “pretty soon, it’s 

gonna be my neck.” (sic) (Id.) Mayweather-Brown was placed on suicide watch, but he 

had to stay in his cell and jail officials checked him every fifteen minutes. (Id. at 712-15.)

At 2:50 p.m., he asked medical staff to retrieve the glass fragments from his cell. (Id. at

715.) A nurse arrived and Mayweather-Brown handed her five small glass fragments.

(Id.)

The next day, on August 6, 2015, Brown followed up with Mayweather-Brown

on suicide watch. (ECF 212-3 at 716-18.) He denied any suicidal ideation or plan and 

talked about the injustices of his treatment by jail staff. (Id. at 717.) He indicated that

mental health staff needed to train jail officers on the proper way to treat him. (Id.) He 

became irritated when Brown told him that she could not serve as an advocate for those 

things he thought he deserved but instead she could listen to him. (Id.) Brown noted

that his risk for suicide was low. (Id.)

On August 7, 2015, Mayweather-Brown told Brown that he did not need to be on 

suicide watch. (ECF 212-3 at 721.) She noted that he had been calm and stable for about 

thirty-six hours. (Id.) At 1:30 p.m., Brown released Mayweather-Brown from suicide 

watch. (Id. at 722.)

Three days later, on August 10, 2015, Mayweather-Brown refused to take his 

Clonidine. (ECF 212-3 at 725.) At 12:10 p.m., it was reported that he had something tied 

around his neck. (Id. at 726.) Brown arrived at his cell and observed him sitting under a 

blanket. (Id.) Jail officers entered the cell and Brown could see that he was holding a 

piece of fabric from his mattress cover. (Id.) Mayweather-Brown stated that he was 
38

angry because he did not have a haircut and had not had access to the law library. (Id.)

He then placed the strip of fabric around his neck and refused to give the strip of fabric 

to jail staff. (Id.) They decided to leave Mayweather-Brown in his cell and closely 

observed him. (Id.) Brown reasoned that his behavior was related to his placement in 

administrative segregation where he had fewer privileges. (Id.) He later backed off from 

his self-harm behaviors. (Id.) At 3:10 p.m., Mayweather-Brown reported that he had cut 

himself with glass. (Id. at 728.) A nurse arrived and cleaned and bandaged two to three

of his superficial abrasions on his inner left wrist. (Id.) He would not surrender the piece 

of glass he used to harm himself. (Id.)

On August 11, 2015, Mayweather-Brown asked to speak with Brown. (ECF 212-3

at 729.) They discussed his behavior on August 10, 2015, and he said he was angry, but 

he was not contemplating death or dying. (Id. at 729.) Mayweather-Brown told Brown 

that the mental health staff was responsible for changing the jail’s policies and 

procedures. (Id.) Brown responded that her job was to help him change his behaviors

even though he was not interested in changing those behaviors. (Id.) He said that he 

needed special accommodations to deal with his P.T.S.D. and then he became verbally 

abusive to Brown, calling her a “b .” (Id.) Brown ended the session with him and he 

said he was going to kill himself as staff left his cell. (Id.) Jail officers subsequently 

checked on him frequently. (Id.)

Three days later, on August 14, 2014, Mayweather-Brown said he no longer 

wanted to talk with the mental health staff. (ECF 212-3 at 734.) He admitted he made 

suicidal statements or gestures when he got angry. (Id.) Brown noted that he would 
39

remain housed in a cell with a camera in the booking unit and items he used to harm 

himself would routinely be taken from his cell when he showered. (Id.) At 2:42 p.m.,

Mayweather-Brown once again announced that he intended to kill himself. (Id. at 736.)

He ripped the top of his uniform and stated he was going to hang himself. (Id.) He 

apparently was upset because he did not get his allotted time in the law library that 

day. (Id.) At 3:15 p.m., Brown placed him on level-three suicide watch. (Id.) Nurse 

Emery recommended that he be checked every fifteen minutes because he covered the 

window and camera in his cell. (Id.) At 4:30 p.m., Mayweather-Brown relinquished the

ripped piece of fabric to jail officials. (Id.) Brown recommended he remain on level-three

suicide watch and he could not use while on suicide watch. (Id.)

On August 17, 2015, Yoder met Mayweather-Brown on suicide watch. (ECF 212-3

at 739-40.) He admitted he was angry that he could not go to the law library. (Id.) Four 

days later, on August 21, 2015, Yoder met with Mayweather-Brown again and noted he 

had no significant change in his presentation. (Id. at 747-48.) Yoder noted that he voiced 

his concern about his rights not being honored by jail officers. (Id. at 748.) He exhibited 

rage and a tremendous sense of entitlement. (Id.) Mayweather-Brown reiterated that the 

jail officers “trigger[ed his] P.T.S.D.” (Id.)

On August 24, 2015, Yoder followed up with Mayweather-Brown, who was 

extremely hostile because he thought that mental health staff was giving into the jail 

officer’s expectations. (ECF 212-3 at 750.) He yelled at Yoder for not doing a “damn 

thing.” (Id.) He was further angered by the fact that the mental health staff no longer 

opened the door when they spoke with him. (Id.)
40

A day later, on August 25, 2015, Dr. Mathew met with Mayweather-Brown, who 

was angry because he would not open the door to speak with him. (ECF 212-3 at 751-

53.) Mayweather-Brown yelled at Dr. Mathew during most of their visit, and stated he 

was being abused by jail officers, which worsened his P.T.S.D. (Id. at 751.) He refused to 

talk about medication and stated he wanted to be treated like everyone else. (Id.) Dr. 

Mathew noted that Mayweather-Brown had no insight into his behavior, had a sense of 

entitlement, and was demanding. (Id.) He said he would subpoena Dr. Matthew and 

would sue many jail officers for his ineffective treatment. (Id.) Dr. Mathew had no new 

treatment recommendations. (Id. at 753.)

Between September 1, 2015 and September 30, 2015, Mayweather-Brown was 

periodically in and out of the Elkhart Jail. (ECF 212-3 at 770.)

On September 1, 2015, Mayweather-Brown assaulted a jail officer by knocking 

him to the ground and gaining control of his taser. (ECF 212-3 at 776-77.) Another jail 

officer wrestled the taser away from Mayweather-Brown and then subdued him. (Id.)

After he was returned to his cell, he began yelling that he had back pain and needed 

medical attention. (Id.) Dr. Foster saw Mayweather-Brown belligerently kicking and 

pounding on the door of his cell. (Id.) Mayweather-Brown recounted the incident with a 

nurse expressing the pride he felt when he assaulted the officer and then threatened 

more violence. (Id.) Dr. Foster’s opined that his back pain did not constitute a serious 

medical condition and his prescribed Tylenol was adequate to alleviate his pain. (Id.) 

The next day, on September 2, 2015, he complained to mental health staff that jail 
41

officers characterized him as being dangerous; however, they had no evidence to 

support their claim. (Id. at 778.)

At the beginning of September 2015, Mayweather-Brown refused to take his 

medication. For example, on September 3, 2015, he would not take his morning 

medication because he was “being lazy.” (ECF 212-3 at 780.) On September 7, 2015, Mr. 

Mayweather-Brown refused his morning asthma medications. (Id. at 786.)

On September 11, 2015, mental health staff discussed Mayweather-Brown’s 

memory about his past emotional feelings and his inability to capture those feelings in 

the present. (ECF 212-3 at 792.) He then asked, “does that mean I’m a sociopath?” (Id.)

Three days later, on September 14, 2015, he once again refused his evening asthma 

medications, stating that he did not want to be harassed. (Id. at 801.)

On September 15, 2015, at 4:40 p.m., Mayweather-Brown told jail officers that he 

was going to hang himself because he wanted to be out of his cell more often and at 

different times of the day. (ECF 212-3 at 802.) Dr. Mathew recommended close 

observation, but that staff should remain as hands-off as possible so as not to escalate 

the situation. (Id.) At 7:45 p.m., the nursing staff was advised that Mayweather-Brown

wanted to cut his head off. (Id. at 805.) He was then placed on observation. (Id.)

The next day, on September 16, 2015, at 3:45 a.m., Mayweather-Brown was given 

his morning inhaler. (ECF 212-3 at 812.) He took the inhaler, held it for a second, and 

then handed it back to the nurse. (Id.) Yoder followed up with him about his recent 

suicide threats. (Id. at 806-807.) He told Yoder that he “just gets pissed off sometimes.” 

(Id.) Yoder noted that Mayweather-Brown was angry over a decision regarding his jail 
42

time. (Id. at 807.) He noted that the primary incident that month entailed his physical 

assault on a rookie jail officer, after which the nursing and mental health staff were not 

permitted to be in the same room with him without a jail officer. (Id. at 808.) He 

assumed responsibility for the incident and spent his time complaining. (Id.) At 10:30 

p.m., Mayweather-Brown reported to the medical unit for his evening medications. (Id.

at 814.) He did not seal his lips around the inhaler and talked during his nebulizer 

treatment. (Id.)

On September 17, 2015, Mayweather-Brown refused to use his morning inhaler. 

(ECF 212-3 at 817.) At 1:00 p.m., Nurse Emery educated him on the proper use of 

inhalers and nebulizer treatment as well as the potential complications of incorrect use

of these devices. (Id.) Mayweather-Brown responded that “I’ve been an asthmatic for 

[twenty years], I know how to use an inhaler.” (Id.) At 10:15 p.m., a nurse noticed that 

Mayweather-Brown was complaining of chest pain. (Id. at 818-19.) He was examined 

and given acid reflux medication, which he refused to take. (Id. at 818-19, 821.) About a 

week later, on September 23, 2015, he again refused to take his morning medications. 

(Id. at 822.)

On October 3, 2015, Mayweather-Brown was given his evening inhaler. (ECF 

212-3 at 847.) He put the inhaler in his mouth but did not push the button. (Id.) The 

nurse asked him if he had used the inhaler and he responded, “Yes ma’am.” (Id.)

Two days later, on October 5, 2015, Dr. Mathew met with Mayweather-Brown

and noted he maintained his usual tirade about being treated differently. (ECF 212-3 at

862-64.) He requested additional time to talk with mental health staff and Dr. Mathew 
43

counseled him on how to best use his time with mental health. (Id. at 864.) He then 

became angry and defensive and Dr. Mathew ended the meeting. (Id.)

On October 8, 2015, Mayweather-Brown took his evening medication. (ECF 212-3 

at 865.) He then walked to the back of his cell, threatened Lieutenant Cole and stated

“[c]ome get them, I’m not taking them.” Two days later, on October 10, 2015, he hit his 

head on his bunk. (Id. at 878-79.) A nurse later observed a small laceration on his head.

(Id.)

On October 12, 2015, at 3:20 a.m., Mayweather-Brown refused his medications 

because he was upset that no treatment was ordered for his head injury. (ECF 212-3 at

882.) The nurse recounted Dr. Foster’s instructions that he take Tylenol as needed and 

keep the area clean and dry. (Id.) Mayweather-Brown responded that “you guys are all 

incompetent and stupid. None of you do your job. I am going to get [an] infection in the 

spot on my head. I am filing a grievance on all of you.” (Id. at 884.) The nurse asked him 

if he would like to fill out a form to see the doctor, and he replied, “That doctor is 

stupid as h** *.” (Id.) At 8:30 a.m., Mayweather-Brown told one of the nurses that he was 

upset because he had not been scheduled for an emergency visit to see a doctor after he 

hit his head. (Id. at 884.) He then threatened to “call the medical board and the nursing 

board.” (Id.) The nurse examined his head and found no break in the skin, no redness,

and no swelling. (Id.) She asked him what treatment he wanted for his head and he 

stated, “you are all incompetent.” (Id.) A few days later, on October 15, 2015, Dr. Foster 

attempted to examine Mayweather-Brown’s head, but he refused the examination. (Id.
44

at 887.) Next, on October 16, 2015, Yoder met with Mayweather-Brown and noted he 

had not had any recent outbursts. (Id. at 888-89.)

On October 22, 2015, at 5:30 p.m., Mayweather-Brown again announced that he 

intended to kill himself. (ECF 212-3 at 895.) At the time, he was holding a piece of torn 

cloth in his hands. (Id.) Per Dr. Mathew’s instructions, Yoder indicated that he should 

not be placed on suicide watch. (Id. at 896.) At 10:15 p.m., the nursing staff was 

contacted because jail officers had used pepper spray on Mayweather-Brown. (Id. at. 

897.) When nurses arrived, he refused to allow officers to handcuff him stating “it is 

medicals duty to treat me and since the officers decided to do this to me, they have to 

follow through with it and get me out so I can be treated. They can’t just leave me in 

here.” (Id. at 899.) He then shouted “Cole f***** up when he sprayed me. They should 

have to come in here and get me.” (Id. at 897.) The nurse noted that Mayweather-Brown

was standing at the door of his cell and was exhibiting no signs of distress. (Id. at 899.)

The nurse told him that until he allowed jail officers to handcuff him, he could not be 

treated. (Id.) At 10:52 p.m., Mayweather-Brown stated that he was busy trying to hang 

himself. (Id. at 899.) He had also once again covered the window and camera in his cell. 

(Id.)

Toward the end of October 2015, Mayweather-Brown once again refused to take 

his medications. (ECF 212-3 at 900, 902, 904.) On October 28, 2015, between 11:45 a.m., 

and 4:45 p.m., he was in and out of the restraint chair and was able to break out of it 

multiple times. (Id. at 905, 914, 919.) He also refused medical care. (Id. at 905, 906-913.)

At 10:05 a.m., Mayweather-Brown stated that he was bleeding and required medical
45

care. (Id. at 920.) Nurse Emery noted he had two superficial lacerations to his inner left 

wrist. (Id.) However, Mayweather-Brown was verbally threatening and declined 

medical treatment after he had requested it. (Id.) He eventually allowed a nurse to clean 

and bandage his lacerations. (Id.) At 7:30 p.m., a nurse was called to his cell to attend to 

another cut he had made to his arm. (Id. at 917.) Mayweather-Brown had tied a rag 

around his arm to make the veins pop out and then had made a small cut to his wrist 

with a paper clip. (Id.) The nurse removed the rag, cleaned the wound, and applied a 

bandage. (Id.)

On October 29, 2015, at 4:00 a.m., Mayweather-Brown was given his morning 

asthma inhaler. (ECF 212-3 at 930-31.) He took the inhaler, threw it to the back of his 

cell, and stated “come and get it now.” (Id. at 930.) The jail officer was able to talk him 

into giving back the inhaler. (Id.) At 2:30 p.m., Mayweather-Brown refused medical 

treatment for the superficial wound on his left wrist, stating “I’m gonna call you when 

it’s bad enough.” (Id. at 925.) He was attempting to hurt his wrist using the sink. (Id. at

903.) Jail officers informed the nurse staffing that he would not open his cell unless he 

needed stitches or urgent medical care. (Id.) At 2:45 p.m., Mayweather-Brown again 

informed the medical staff that he was bleeding, and the nurse observed a small, 

superficial laceration to his inner left wrist. (Id.) Five minutes later, at 2:50 p.m., he 

would not allow Dr. Foster to look at the wound to his left wrist and stated, “I’m taking 

care of it.” (Id. at 926, 930.) Dr. Mathew then placed Mayweather-Brown on suicide 

watch. (Id. at 927-928, 930.)
46

At 3:35 p.m. on October 29, 2015, Mayweather-Brown refused medical care for 

the wounds to his wrist, and stated “I’m not done, so they don’t need [to be] cleaned 

yet.” (ECF 212-3 at 923.) He requested to be seen by the nurse in twenty minutes. (Id. at

930.) By 4:00 p.m., medical staff was called to assess his wrist, but he refused medical 

care stating that “Corey lied to me.” (Id. at 924.) At 4:30 p.m., Mayweather-Brown

allowed the nurse to clean the wound to his left inner wrist. (Id. at 930.) The nurse 

observed a small, superficial laceration with a minimal amount of dried blood. (Id.)

Mayweather-Brown refused a bandage and stated that he may or may not attempt to 

hurt himself again. (Id.)

On October 30, 2015, Dr. Mathew met with Mayweather-Brown due to his 

escalating behavior. (ECF 212-3 at 934-36.) Dr. Mathew reported that he had pushed

boundaries, been inappropriate with jail staff, and had more restrictions. (Id. at 934.)

Because he had more restrictions, Mayweather-Brown’s threats of suicide and selfharm had escalated. (Id.) He had also been placed in the restraint chair a few times and 

had chewed his way out. (Id.) Dr. Mathew opined that his behavior was highly 

predictable, and he harmed himself so that he could make a case for being neglected. 

(Id.) When attempts were made to treat or protect Mayweather-Brown, he immediately 

sabotaged them. (Id.) Because Mayweather-Brown escalated his behavior during the 

meeting, Dr. Mathew ended the meeting early, which prompted him to threaten to hang 

himself. (Id.) Dr. Mathew noted that he should not evaluate Mayweather-Brown when 

his behavior had escalated because it led to more adverse behavior. (Id. at 936.) Dr. 
47

Mathew recommended consistency and not engaging in arguments with MayweatherBrown. (Id.)

Yoder followed up with Mayweather-Brown on suicide watch. (ECF 212-3 at 939-

40.) When he saw her, he stated “Yoder, you’re a f****** b . Get the hell away from 

my door.” (Id. at 940.) Yoder noted that he was unable to garnish any support from Dr. 

Mathew and his motivation for clinical support was poor. (Id.) At 1:05 p.m., he refused 

medical care, stating “f** * you bitch. Don’t open my door. Go away.” (Id. at 932.) By 2:03 

p.m., Mayweather-Brown asked to speak with the medical staff. (Id.) Nurse Emery 

arrived at his cell to speak with him to which he responded “f*** you, get away from 

my door.” (Id.)

On October 31, 2015, at 1:00 p.m., Mayweather-Brown attempted to hang himself 

on the bar next to his toilet. (ECF 212-3 at 948.) Jail officers discovered him and tore 

away the cloth that he had tied around his neck. (Id.) Mayweather-Brown was coughing 

and hyperventilating but his vital signs were stable. (Id.) There were no abrasions, 

indentations, discoloration, or swelling on his neck. (Id.) Jail officers took his belongings 

and clothing for his safety, which caused him to become irate. (Id.) At 2:10 p.m., he 

asked to speak to the nursing staff. (Id. at 951.) Mayweather-Brown was irate and stated,

“that mother f***** over there just watch[ed] me rip this cloth to hang myself and he just 

smiled.” (Id.) He further stated, “Gary Yoder does nothing for me, I am receiving no 

mental health from you at all.” (Id.) The nurse informed him that if he continued to yell, 

she would walk away, and he responded that the nurse could walk away. (Id.)
48

At 4:20 p.m. on October 31, 2015, Mayweather-Brown was placed in the restraint 

chair after he made numerous attempts at hurting himself. (Id. at 944, 946, 953.) At 10:30 

p.m., the nurse gave him his medication and water and juice to drink. (Id. at 953.) He 

told the nurse that he only wanted enough water to keep his lips moist because he 

intended to be in the restraint chair until Monday and he did not want to drink too 

much water because he did not want to have to get out of the chair to use the bathroom. 

(Id.) He did not state why he wanted to remain in the restraint chair. (Id.)

On November 1, 2015, just after midnight, Mayweather-Brown was released 

from the restraint chair and given food, Boost, and juice. (ECF 212-3 at 954-55.) He 

returned to his cell with his suicide smock and stated, “I just want to sleep now.” (Id. at

955.) At 4:50 p.m., jail officers once again placed Mayweather-Brown in the restraint 

chair. (Id. at 966-67.) At that time, he stated he did not want his vital signs checked

every fifteen minutes and he agreed to sign a refusal of treatment form. (Id. at 964, 967.)

Mayweather-Brown then urinated on himself. (Id. at 967.)

On November 2, 2015, Mayweather-Brown requested medical care because he 

had chest pain but refused to allow the nurse to examine him. (ECF 212-3 at 970, 981.)

At 9:00 a.m., jail officers contacted the nursing staff and reported that he had eaten a 

tube of tooth paste (2.75 grams) because “it was the right thing to do.” (Id. at 975.) At 

9:24 a.m., a nurse observed Mayweather-Brown in his cell eating another tube of 

toothpaste. (Id. at 978.) The nurse then contacted poison control who told her he may

vomit due to ingesting the toothpaste. (Id.) Dr. Foster ordered the nursing staff to

monitor Mayweather-Brown for vomiting. (Id. at 975.) Yoder met with him and noted 
49

he was agitated and hostile. (Id. at 982-83.) He also noted that Mayweather-Brown’s 

behavior was attention-seeking and he had no insight into his own actions. (Id.) At 5:10 

p.m., he requested a Boost supplement and antacid tablets. (Id. at 975.) He was given 

both, but he refused the Boost. (Id.) At 5:20 p.m., jail officers convinced him to drink the

Boost and request a meal tray. (Id.)

The next day, on November 3, 2015, Mayweather-Brown refused his morning 

asthma medication. (ECF 212-3 at 987.) At 10:45 a.m., he reported that he was no longer 

going to drink any fluids and his reason was “because he wants to.” (Id. at 993.) At 12:20 

p.m., the nursing staff was called because he cut his wrist with a small piece of plastic. 

(Id.) The nurse observed the cut to be superficial and only slightly bleeding. (Id.) He 

refused to allow the nurse to dress the cut, saying “get away from my f****** door.” (Id.

at 988, 993.) Mayweather-Brown threatened to harm anyone who opened his cell door. 

(Id. at 993.) Jail officers told the nursing staff that they were planning to remove him 

from his cell and confiscate the items he was using to harm himself. (Id.) Yoder met

with Mayweather-Brown and observed that he was agitated, hostile, and unable to 

accept the consequences of his actions. (Id. 989-90.) He further noted that MayweatherBrown’s “ability to cope is non-existent.” (Id. at 990.) Yoder noted that a meeting with

Perry, the second shift sergeant, and Dr. Mathew was needed and there “must be a line 

of sight for Mayweather[-Brown] at all times.” (Id.) At the meeting, it was suggested 

that he be given paper clothes to lessen the risk of self-harm. (Id.)

On November 4, 2015, Yoder met with Mayweather-Brown. (ECF 212-3 at 995.)

He noted that he planned on meeting with Mayweather-Brown several times per week 
50

to allow him to vent. (Id.) The next day, on November 5, 2015, Yoder followed up again 

with Mayweather-Brown and noted that he was focused on being released from suicide 

watch. (Id. at 1001.) At that time, Dr. Mathew consulted with Dr. Dalmasy, the chief 

psychiatrist at CCS, to review Mayweather-Brown’s recent behavior and treatment 

approaches. (Id. at 1002-03.) Dr. Dalmasy acknowledged the high level of risk that 

Mayweather-Brown presented at the jail, regardless of his treatment, and he expressed 

his agreement with Dr. Mathew’s treatment plan for Mayweather-Brown. (Id. at 1002.)

Dr. Mathew and Dr. Dalmasy felt that Mayweather-Brown did not have a psychotic 

disorder, and that his symptoms were consistent with antisocial personality and 

impulse control disorders. (Id.) After consulting with Dr. Dalmasy, Dr. Mathew’s 

treatment plan entailed: (1) reducing physical interventions, (2) using the restraint chair 

when Mayweather-Brown engaged in self-harm, but not when he made threats or 

isolated gestures, (3) taking items out of his cell since he used anything he could find to 

harm himself, and (4) increasing meetings with mental health staff. (Id. at 1003.) Also, at 

5:45 p.m., on November 5, 2015, Mayweather-Brown received a breathing treatment and 

told the nurse he wanted to be released from level-three suicide watch and said, “I am 

gonna sue all of medical for keeping me on this level-three protocol.” (Id. at 1005.)

On November 6, 2015, Mayweather-Brown refused his morning medication. 

(ECF 212-3 at 1006.) At 10:45 p.m., he bragged about eating toothpaste, stating that he 

had eaten six tubes. (Id. at 1007.) The next day, on November 7, 2015, MayweatherBrown refused to take his evening medication. (Id at 1010.)
51

Two days later, on November 9, 2015, Mayweather-Brown saw the dentist to 

have a tooth repaired. (ECF 212-3 at 1016-18.) The dentist noted that he may have 

feigned tooth pain to have his tooth restored. (Id. at 1018.) Yoder met with MayweatherBrown, who stated he was unjustly placed on suicide watch. (Id. at 1020.) The next day, 

on November 10, 2015, Yoder attempted to follow up with Mayweather-Brown but 

refused to meet with Yoder, saying “Yoder, I have absolutely nothing to say to you.” 

(Id. at 1024.)

On November 11, 2015, at 8:00 a.m., Mayweather-Brown asked to meet with the 

mental health staff. (ECF 212-3 at 1032.) He told them “this watch [wa]s no longer 

necessary” and threatened them, saying “[m]y sister on the outside won’t take kindly to 

the way I am being treated. Trust me, you will lose your license.” (Id. at 1032.) At 11:22 

a.m., Mayweather-Brown began yelling for a nurse and told her that he was “fittin’ to 

tie this thing around my neck if I don’t see mental health.” (Id.) Yoder then met with 

him. (Id. at 1029-30.) Mayweather-Brown told Yoder that he would be calling mental 

health staff constantly to attempt to get off of suicide watch. (Id. at 1030.) Yoder made it 

clear that he would spend thirty minutes with him each day and Mayweather-Brown

responded “you just wait. I’ll make certain your coming to me all day long.” (Id.)

The next day, on November 12, 2015, Yoder met Mayweather-Brown on suicide 

watch. (ECF 212-3 at 1033-34.) He told Yoder to “get the f*** away from this door. You 

don’t give a damn.” (Id. at 1034.) At 9:16 a.m., Mayweather-Brown asked for his inhaler. 

(Id. 1037-38.) After using the inhaler, he threw it on his bunk and stated, “now you can 
52

bring your team in and get the mother f*****.” (Id. at 1038.) The next day, he once again 

refused his morning medication. (Id. at 1040.)

On November 16, 2015, Yoder authored a behavioral health note detailing that 

Dr. Mathew did not see a need to remove Mayweather-Brown from suicide watch. (ECF 

212-3 at 1051-53.) Yoder noted that Mayweather-Brown constantly demanded to be 

taken off suicide watch. (Id. at 1051.) Yoder met him and he stated “Yoder, get the f***

away from my cell, you don’t know s*** and you’re a** is fired. I have no plan to talk to 

you until you have your meeting.” (Id. at 1055.)

On November 18, 2015, Yoder attempted to meet with Mayweather-Brown but 

he refused to talk with him. (ECF 212-3 at 1071.) He stated “Gary, get lost. You know I 

don’t want to talk to you if you aren’t getting me off level [three].” Id. The next day, on 

November 19, 2015, Yoder attempted to meet with Mayweather-Brown, who stated 

“Yoder, unless I’m off suicide watch, get the hell out of here. You don’t know s***.” (Id.

at 1076.)

On November 20, 2015, Mayweather-Brown asked to be transferred to another 

facility. (ECF 212-3 at 1079, 1082.) The judge agreed to transfer him to the Lake County

Jail. (Id.) Yoder spoke with Mayweather-Brown about the transfer, who responded “I’m 

getting the h*** out of here, no thanks to you Yoder.” (Id. at 1082.) About three weeks 

later, on December 11, 2015, Mayweather-Brown returned to the Elkhart Jail. (Id. at 

1092.)

On December 30, 2015, Yoder noted that since his trial and guilty sentence, 

Mayweather-Brown’s behavior had not been problematic. (ECF 212-3 at 1113.) He 
53

exhibited no conflicts with his peers or jail officers and had been placed in the mental 

health unit. (Id.)

On January 1, 2016, Mayweather-Brown requested a breathing treatment. (ECF 

212-3 1122-23.) The nurse informed him that he would do the breathing treatment in a 

classroom in his unit instead of in the medical unit and he responded “you don’t know 

what you are talking about, shut up.” (Id.) He then began insulting jail officers and the 

nurse. (Id.) After being belligerence with the officers, they decided to take him to the 

medical unit, where he did his breathing treatment without issue. (Id.)

On January 4, 2016, Mayweather-Brown refused to take his morning medication. 

(ECF 212-3 at 1124.) At 9:45 p.m., nursing staff set up a nebulizer breathing treatment 

for him in a classroom in his unit. (Id. at 1128.) He responded by unplugging the 

nebulizer machine, moving it to the other side of the room, and saying “I told them that 

if I had to take my treatments down here that I would break the machine. I’m going to 

break this f****** machine now. No, I will not give it back to you.” (Id.) He was then

confronted by jail officers and a physical altercation ensued during which he scratched 

and spit at officers. (Id. at 1128, 1130.) After the physical altercation. he made suicidal 

statements. (Id. at 1128.) Mayweather-Brown was placed on level-two suicide watch. (Id.

at 1126.) He refused his evening medications and stated to the nurse “I don’t want to 

see you b . If you come by my door again, I’ll piss on you. I w[ant] a different nurse. 

Come by my door against and I’ll piss on you b** **.” (Id. at 1125, 1128.) He further 

stated “If you sign a refusal, I’ll go to the nursing board and take your license and I’ll 

have my family come after you too. You’re going to get sued b****.” Id.
54

The next day, on January 5, 2016, Dr. Mathew met with Mayweather-Brown. 

(ECF 212-3 at 1130.) He noted Mayweather-Brown had been doing well until he threw a 

fit the day before. (Id.) Dr. Mathew recounted that he seemed to be scared when he was 

in his housing unit and acting out may have been a way for him to return to a cell in the 

booking unit. (Id.) He considered placing Mayweather-Brown on level-three suicide 

watch, but with paper scrubs so he could not make his typical self-harm gestures. (Id. at

1132.) Ultimately, Dr. Mathew decided to keep him on a level-two suicide watch. (Id. at

1136.)

On January 8, 2016, Mr. Mayweather-Brown remained on level-two suicide 

watch and Perry decided to give him a mattress. (ECF 212-3 at 1165.)

On January 12, 2016, Mayweather-Brown asked to speak with the nursing staff. 

(ECF 212-3 at 1181.) Nurse Emery reported that he was agitated and raised his voice 

with another nurse because he did not want to remain on suicide watch. (Id.) He was 

upset because he had a cold and wanted to schedule an urgent appointment with the 

doctor. (Id. at 1183.) He stated that he would “have . . . . Robin’s license, Dr. Foster’s 

license and Gary’s license. (Id. at 1181.) Mayweather-Brown said that if he remained on 

suicide watch, he would “make everyone’s lives hell for the next [seven] days.” (Id. at

1181, 1183.)

On January 13, 2016, Mayweather-Brown refused to take his morning 

medication. (ECF 212-3 at 1187.) About a week later, on January 21, 2016, MayweatherBrown was transferred to an IDOC facility. (ECF 212-2 at ¶ 5.)
55

PRELIMINARY MOTIONS

Before the court addresses the merits of the parties’ summary judgment motions, 

several motions filed by Mayweather-Brown must be addressed.

Mayweather-Brown has filed a motion to strike (ECF 271) a portion of the 

defendants’ briefs and evidence – specifically, arguments and records that suggest that 

Mayweather-Brown suffered from a behavior problem instead of a mental health 

problem. It is the function of the Court, with or without a motion to strike, to carefully 

review the evidence and to eliminate from consideration any argument, conclusions, 

and assertions unsupported by the documented evidence of record offered in support 

of the statement. See, e.g., S.E.C. v. KPMG LLP, 412 F.Supp.2d 349, 392 (S.D.N.Y. 2006);

Sullivan v. Henry Smid Plumbing & Heating Co., Inc., No. 04 C 5167, 05 C 2253, 2006 WL 

980740, at *2 n.2 (N.D. Ill. Apr. 10, 2006); Tibbetts v. RadioShack Corp., No. 03 C 2249, 2004 

WL 2203418, at *16 (N.D. Ill. Sept. 29, 2004); Rosado v. Taylor, 324 F.Supp.2d 917, 920 n.1 

(N.D. Ind. 2004). Mayweather Brown’s motion will be denied, but the court notes that, 

in ruling on a motion for summary judgment, the court considers only relevant 

evidence that would be admissible at trial. See Woods v. City of Chicago, 234 F.3d 979, 988 

(7th Cir. 2000). The court is able to sift through the evidence and to consider each piece 

under the applicable federal rules, thus there is no need to address MayweatherBrown’s motion to strike and it will be denied.

Mayweather-Brown has filed several motions (ECF 277; 280; 287) seeking a 

preliminary ruling on the admissibility of documents. With these motions, 

Mayweather-Brown has presented a report from the Elkhart County Detention Center 
56

regarding events occurring on January 27, 2014 (ECF 277 at 6); several documents 

obtained through a request for public records (ECF 280-1); and two reports concerning 

his competency to stand trial (ECF 287-1). It would be premature for the court to decide 

issues of admissibility at this juncture. Motions in limine should be filed after all 

dispositive motions have been ruled upon and a trial date has been set. Accordingly, the 

motions for determination of admissibility will be denied, but – in light of MayweatherBrown’s status as a pro se litigant, the documents have been considered in connection 

with the pending summary judgment motions. These motions (ECF 277; 280; 287) will 

be denied. 

Mayweather-Brown filed two motions (ECF 278; 289) asking the court to take 

judicial notice of two cases: Indiana Protection and Advocacy Services Commission v. 

Commissioner, No. 1:08-cv-01317-TWP-MJD, 2012 WL 6738517 (S.D. Ind. Dec. 31, 2012); 

and In re: the mental commitment of M.P., 510 N.E.2d 645 (Ind. 1986). A court may take 

judicial notice of adjudicative facts if they are generally known within the territorial 

jurisdiction of the trial court or capable of accurate and ready determination by resort to 

resources whose accuracy cannot reasonably be questioned. Fed. R. Evid. 201. The court 

has considered the cases that Mayweather-Brown presents, but it is not necessary to 

take judicial notice of the cases. These motions (ECF 278; 289) will be denied.

Mayweather-Brown filed a motion (ECF 279) asking the court to rule on his 

motion seeking judicial notice (ECF 278). While Mayweather-Brown’s case is important,

so are the other cases filed in this court. His case is not the only one before this court. It 
57

takes time to accurately review and justly rule on each filing. Doing that is delayed by 

filing unnecessary motions like this one. Therefore, the motion (ECF 279) will be denied.

STANDARD OF REVIEW

Pursuant to Fed. R. Civ. P. 56(a), summary judgment is appropriate “if the 

movant shows that there is no genuine dispute as to any material fact and the movant is 

entitled to judgment as a matter of law.” The party seeking summary judgment “bears 

the initial responsibility of informing the district court of the basis for its motion and 

identifying” the evidence which “demonstrate[s] the absence of a genuine issue of 

material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Substantive law 

determines which facts are material; that is, which facts might affect the outcome of the 

suit under the governing law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A 

party asserting that a fact cannot be or is genuinely disputed must support the assertion 

by “citing to particular parts of materials in the record” or show “that the materials 

cited do not establish the absence or presence of a genuine dispute, or that an adverse 

party cannot produce admissible evidence to support the fact.” Fed. R. Civ. P. 56(c)(1).

In ruling on a motion for summary judgment, the court must view all facts in the 

light most favorable to the nonmoving party. Anderson, 477 U.S. at 255. The court will 

not “make credibility determinations, weigh the evidence, or decide which inferences to 

draw from the facts; these are jobs for a factfinder.” Payne v. Pauley, 337 F.3d 767, 770 

(7th Cir. 2003). Summary judgment is not a substitute for a trial on the merits or a 

vehicle for resolving factual disputes. Waldridge v. Am. Hoechst Corp., 24 F.3d 918, 920 

(7th Cir. 1994). Instead, the court’s sole task in ruling on a motion for summary 
58

judgment is “to decide, based on the evidence of record, whether there is any material 

dispute of fact that requires a trial.” Payne, 337 F.3d at 770. If a reasonable fact finder 

could find in favor of the nonmoving party, summary judgment may not be granted. Id.

Nevertheless, a party opposing summary judgment may not rely on allegations or 

denials in his or her own pleading, but rather must “marshal and present the court with 

the evidence she contends will prove her case.” Goodman v. Nat'l Sec. Agency, Inc., 621 

F.3d 651, 654 (7th Cir. 2010). Furthermore, where the parties file cross-motions for 

summary judgment, the court must consider each motion; but despite the parties’

agreement that no genuine dispute of material fact exists, the court can deny all motions 

if the parties do not establish their rights to judgment as a matter of law. Grabach v. 

Evans, 196 F. Supp. 2d 746, 747 (N.D. Ind. 2002).

ANALYSIS

Inadequate Medical Care Claim

Mayweather-Brown moves for summary judgment asserting that the Defendants 

violated his constitutional rights by allowing him to inflict harm upon himself while he 

was a pretrial detainee at the Elkhart Jail. (ECF 202 at 1.) He claims he was “gravely 

disabled” and “seriously mentally ill” while housed at the jail but was deprived of 

adequate mental health and medical care, which allowed him to repeatedly engage in 

acts of self-harm and suicide. (Id.) Mayweather-Brown claims there was a policy 

orchestrated by jail officials to deprive him of much needed medical care. (Id.) This 

policy caused him extreme psychological and emotional damage, and physical injuries 

during his incarceration at the jail. (Id.) He claims the Defendants worked in concert to 
59

develop policies to provide him with substandard treatment and care. (Id. at 3.) 

Mayweather-Brown states that, when he complained he felt suicidal or wanted to harm 

himself, they would allow him to attempt to carry out his plan. (Id.) In other words, he 

states he was a danger to himself and the Defendants failed to protect him from himself. 

(Id.) Mayweather-Brown further asserts that he should have been placed in a state 

mental hospital, but the Defendants refused to do so. (Id. at 3-4.)

The Defendants have responded to Mayweather-Brown’s motion for summary 

judgment by filing cross-motions for summary judgment in which they assert there are 

no genuine issues of material fact as to his alleged inadequate medical claim. (ECF 210; 

213.) In this regard, the Defendants contend that Dr. Mathew spent a significant amount 

of time and effort developing and implementing an appropriate “hands-off” treatment 

plan for Mayweather-Brown with the goal of keeping him and all those around him 

safe. (ECF 211 at 2, 8-12.) They next assert that Yoder, a licensed clinical social worker, 

provided daily mental healthcare services to Mayweather-Brown by counseling him, 

monitoring his destructive behavior, and following Dr. Mathew’s treatment plan to 

protect him. (Id. at 12-14.) They further claim that Yohn, the Health Services 

Administrator, was simply the office administrator and did not provide any care to 

Mayweather-Brown. (Id. at 6-8.) Finally, the Defendants contend that Lieutenant Bigler 

and Captain Perry reasonably relied on Dr. Mathew’s treatment plan as well as the 

medical and treatment advice of the CCS staff to ensure that Mayweather-Brown’s 

mental health needs were met. (ECF 214 at 8.)
60

Mayweather-Brown’s constitutional rights “as a pretrial detainee are derived 

from the Due Process Clause of the Fourteenth Amendment.” Burton v. Downey, 805 

F.3d 776, 784 (7th Cir. 2015). “[M]edical-care claims brought by pretrial detainees under 

the Fourteenth Amendment are subject only to the objective unreasonable inquiry

identified in Kingsley. Miranda v. Cty. of Lake, 900 F.3d 335, 352 (7th Cir. 2018) (citing 

Kingsley v. Henderickson, 135 S.Ct. 2466, 2472 (2015)). The inquiry for assessing a due 

process challenge to a pretrial detainee’s medical care entails two steps. Id. at 353. The 

first step, which focuses on the intentional conduct of the defendants, “asks whether the 

medical defendants acted purposefully, knowingly, or perhaps even recklessly when 

they considered the consequences of their handling of [the plaintiff’s] case.” Id. A 

showing of negligence or even gross negligence will not suffice. Id. The second step asks 

whether the challenged conduct was objectively reasonable. Id. at 354. This requires a 

court to “focus on the totality of facts and circumstances faced by the individual alleged 

to have provided inadequate medical care and to gauge objectively—without regard to 

any subjective belief held by the individual—whether the response was reasonable.” 

McCann v. Ogle Cty., Ill., 909 F.3d 881, (7th Cir. 2018). The objective reasonableness 

standard requires more than medical malpractice and “the state-of-mind-requirement 

for constitutional cases remains higher.” Miranda, 900 F.3d at 353.

Dr. Mathew

With respect to Dr. Mathew, Mayweather-Brown argues that Dr. Mathew was 

the architect of the “hands-off” treatment plan implemented on July 23, 2015, which he 

specifically created to deny him adequate medical and mental health care at the Elkhart 
61

Jail. (ECF 232-1 at 8.) He asserts that Dr. Mathew “took a one size fit[s] all approach” to 

his mental healthcare treatment “even when the result was a matter of life and death.” 

(Id. at 39.) He states that Dr. Matthew failed to provide an “objective level of mental 

health evaluations and medication” that he believed were warranted. (Id.) Next, he 

claims that Dr. Mathews ignored the fact that he refused to take his medications 

because Dr. Mathew “did not care.” (Id.) Mayweather-Brown found Dr. Mathew’s 

treatment plan to be so “cursory” that it amounted to no treatment at all and simply 

constituted dangerous and “experimental” treatment which took a “gamble” on his life. 

(Id. at 40.) In sum, he claims that Dr. Mathew’s “hands-off” treatment plan was 

unreasonable given his multiple suicide attempts and the fact that his condition did not 

improve. (Id. at 41.)

As a psychiatrist employed by CCS, Dr. Mathew’s role within the Elkhart Jail 

health care system was to diagnose inmates with behavioral and psychiatric disorders, 

prescribe and manage psychiatric medication for inmates, and see inmates as needed 

for acute psychiatric issues. (ECF 212-5 ¶¶ 3, 4.) Dr. Mathew created treatment plans for 

inmates and advised mental health staff on how best to treat inmates, but he did not 

take an active role in monitoring the day-to-day mental health care of inmates at the 

Elkhart Jail. (Id. at ¶ 4.)

On June 30, 2015, Dr. Mathew conducted an initial psychiatric evaluation of 

Mayweather-Brown after he returned to the Elkhart Jail from a lengthy stay at another 

facility. (ECF 212-5 at ¶ 7.) Based on Dr. Mathew’s evaluation and review of his history 

of behavioral issues and manipulative behavior, Dr. Mathew diagnosed him with 
62

antisocial personality and impulse control disorders and prescribed Clonidine. (Id.) Dr. 

Mathew noted that Mayweather-Brown manipulated jail officers by threatening selfharm and often asked to be placed in a restraint chair or on suicide watch. (Id.) He also 

documented that there is no approved or effective treatment for antisocial personality 

disorder. (Id.) Several hours later, Mayweather-Brown refused his medication and 

expressed suicidal ideation that he had not communicated to Dr. Mathew during the 

initial evaluation. (Id. at ¶ 8.)

On July 23, 2015, Dr. Mathew met with Mayweather-Brown and noted that, 

during the past month, he had asked to be placed in the restraint chair only to wiggle 

out of it, had instigated conflicts with other inmates by spraying them with detergent, 

and had covered his cell with water while also throwing it at jail officers. (ECF 212-5 at 

¶ 10.) Dr. Mathew recognized that Mayweather-Brown frequently used threats of selfharm to manipulate jail officers and medical staff for attention, or to get those things he 

wanted. (Id.) While most of his attempts to harm himself were minor and superficial, 

Dr. Mathew acknowledged that he was much more likely to hurt himself or others if jail 

officers or medical staff entered his cell to either restrain him or redirect his behavior. 

(Id.) He recognized that Mayweather-Brown’s dangerous behavior escalated when he 

received attention or intervention from staff. (Id.) Dr. Mathew indicated that 

Mayweather-Brown should be housed by himself and that staff should refrain from 

intervening with him unless he was actively harming himself. (Id.) He recommended a 

“hands-off” treatment plan approach due to the risk of injury caused by physical 

intervention and instructed jail officers to ignore Mayweather-Brown’s taunts and 
63

threats. (Id.) Dr. Mathew assessed Mayweather-Brown’s prognosis as being quite poor 

because he did not anticipate him choosing to or being able to modify his behavior. (Id.)

That same day, Dr. Mathew met with Perry, administrators, jail staff, and mental 

health staff to review and establish the new “hands-off” treatment plan. (ECF 212-5 at ¶

11.) Dr. Mathews presented the treatment plan to staff as consisting of: (1) reducing 

physical interventions, (2) using the restraint chair when Mayweather-Brown engaged 

in self-harm, but not when he made threats or isolated gestures, (3) taking items out of 

his cell since he used anything he could find to harm himself, and (4) increasing

meetings with mental health staff. (Id. at ¶ 10.) He explained that this treatment plan 

was developed not to deny Mayweather-Brown mental health care, but to deliver his 

mental health care to him in such a way that would minimize the chance that he would 

escalate his behavior and harm himself and others. (Id. at ¶ 11.) In other words, Dr. 

Mathew explained that his treatment plan was designed to prevent Mayweather-Brown 

from attempting to harm himself or others. (Id.) Far from being a do-nothing plan, as 

Mayweather-Brown suggests, the plan was designed to provide measured responses to 

his outbursts to avoid provoking acts of suicide and self-harm.

From July through October of 2015, Dr. Mathew noted that Mayweather-Brown 

continued to engage in predictable patterns of behavior, including manipulating others. 

(ECF 212-5 at ¶¶ 12-17.) Dr. Mathew met with Mayweather-Brown regularly and each 

meeting ended with him shouting, cursing, and arguing with Dr. Mathew. (Id. at ¶¶ 12, 

15-17.) On October 29, 2015, Dr. Mathew met with Mayweather-Brown because of his 

escalating behavior. (Id. at ¶ 17.) He observed that Mayweather-Brown typically 
64

threatened suicide and superficially harmed himself to fabricate an argument that he 

was being neglected, and then refused or sabotaged any attempts by medical staff to 

treat his injuries or protect him from harm. (Id.) The meeting ended early because 

Mayweather-Brown refused to communicate, at which point he threatened to hang 

himself. (Id.) As a result of this meeting, Dr. Mathew recommended that jail staff refrain 

from arguing with Mayweather-Brown, minimize reactive treatment, and limit the use 

of physical restraint to episodes of acute patient safety issues. (Id.)

On November 5, 2015, Dr. Mathew consulted with Dr. Dalmasy, the chief 

psychiatrist at CCS, regarding Mayweather-Brown’s treatment plan and documented 

their conversation. (ECF 212-5 at ¶¶ 18, 19.) Dr. Mathew and Dr. Dalmasy both agreed 

that the biggest risk of harm to Mayweather-Brown was not self-harm or suicide but 

physical intervention from jail officers because he sought to escalate physical conflicts 

with them. (Id.) Both doctors recommended that Mayweather-Brown not be given any 

items in his cell as he has frequently used any item at his disposal to harm himself and 

manipulate others. (Id.) 

While Mayweather-Brown complains that Dr. Mathew improperly created a 

customized treatment plan to deal with his mental health issues, he has failed to 

articulate how an individualized treatment plan violated his constitutional rights. Far 

from being unconstitutional, it is common practice for doctors—including 

psychiatrists—to create individualized treatment plans for their patients. He also argues 

that Dr. Mathew’s treatment plan was tantamount to a policy or custom, which was 

created to deny him adequate medical and mental healthcare. But that contention is 
65

belied by the record in this case as Mayweather-Brown’s medical records and Dr. 

Mathew’s affidavit show that he received an unusually high amount of personalized 

attention from the medical and mental health staff. The record evidence establishes that 

Dr. Mathew’s treatment plan for Mayweather-Brown was designed to keep him safe, 

manage his volatile behavior, and minimize his chances that he would seriously hurt 

himself or others. An analysis of Dr. Mathew’s care of Mayweather-Brown shows that

he expended considerable effort in keeping him safe and his recommendations were 

designed to reduce the frequency and severity of Mayweather-Brown’s behavioral 

issues. Thus, contrary to Mayweather-Brown assertion that Dr. Mathew violated his 

constitutional rights by allowing him to inflict harm upon himself, his treatment plan 

was specifically tailored to address Mayweather-Brown’s behavioral issues and mental 

health problems by minimizing the severity and number of his suicide attempts and 

reducing his chances of hurting himself and others.

While Mayweather-Brown claims Dr. Mathew’s “hands-off” treatment plan was 

objectively unreasonable, he has not provided this court with medical evidence or an 

alternative treatment plan that he believes would have more appropriately addressed

his behavior and mental health issues. In other words, he has not provided this court 

with information regarding what he believes the proper course of treatment would 

have been given his circumstances. He has also neither moved for the appointment of 

counsel nor the appointment of an expert in this case. And case law instructs that 

Mayweather-Brown has the initial burden of production “to inform the district court 

why a trial is not necessary.” Smith v. Hous. Auth. of S. Bend, No. 3:09-CV-330, 2015 WL 
66

1486808, at *2 (N.D. Ind. Mar. 31, 2015) (citing Modrowski v. Pigatto, 712 F.3d 1166 (7th 

Cir.2013)). In other words, the requirements imposed on the moving party “are not 

onerous” when it is the nonmovant who “bears the ultimate burden of persuasion on a 

particular issue.” Id. Here, Mayweather-Brown has produced no evidence to show that 

Dr. Mathew’s “hands-off” treatment approach was objectively unreasonable.

In sum, Dr. Mathew recognized that Mayweather-Brown posed very little risk of 

harming himself because most of his suicide threats subsequent to the July 23, 2015, 

implementation of Dr. Mathews’ treatment plan, were empty and his incidents of selfharm were superficial and in direct response to not getting something he wanted. As 

stated, Dr. Mathew reasoned that he was much more likely to hurt himself or others 

when jail or medical staff intervened unnecessarily. Mayweather-Brown would use any 

item, including suicide smocks, suicide blankets, mattresses, and even paint chips to 

threaten to harm himself in order to provoke a response. With these factors in mind, Dr. 

Mathew created a treatment plan of close observation and advised jail staff to only 

intervene when necessary so as to prevent Mayweather-Brown from harming himself or 

others. Given the record in this case, the court concludes that no reasonable fact finder 

could find that Dr. Mathew’s medical care and treatment plan were objectively 

unreasonable.

Gary Yoder

Mayweather-Brown argues that Yoder, a licensed clinical social worker, violated 

his constitutional rights because he knew that he faced a serious risk of danger if he did 

not receive adequate medical care at an appropriate facility, but he did nothing to help 
67

him. (ECF 232-1 at 28.) Instead, he claims that Yoder simply turned a blind eye by 

implementing Dr. Mathew’s “hands-off” treatment plan and “passively endorsed” the 

unconstitutional plan of treatment. (Id. at 29, 30.) Thus, according to MayweatherBrown, because Yoder periodically reviewed his mental health status, he knew he 

required more “intense psychiatric treatment” outside of what the Elkhart Jail staff 

could provide him. (Id. at 30-31.)

On March 21, 2014, Yoder, became involved in Mayweather-Brown’s care. (ECF 

212-7 at ¶ 5.) Mayweather-Brown had arrived at the jail on March 20, 2014, and 

attempted suicide three times in his first twenty-four hours at the jail. (Id.) At that time, 

he also verbalized the fact that he intended to drown himself in the toilet and bang his 

head on the floor to injure himself. (Id.) He had also injured an officer by punching and 

biting him. (Id.) That evening, Mayweather-Brown dismantled an intercom speaker in 

his cell and tied the wires around his neck. (Id.) Given his suicidal and violent behavior, 

Yoder consulted with Dr. Mathew, who worked at Oaklawn Hospital before working 

for Elkhart Jail, to request that Mayweather-Brown be admitted for inpatient psychiatric 

care. (Id. at ¶ 6.) However, Dr. Mathew refused to admit him because Oaklawn was not 

equipped to manage his violent behavior. (Id.)

From March 2014 to June 2014, Yoder met with Mayweather-Brown, sometimes 

as often as every hour, to assist him during his acute mental crises, place him on suicide 

watches, order suicide smocks and blankets, monitor his medications, and counsel him 

on ways to combat his dangerous behaviors. (ECF 212-7 at ¶¶ 7-10, 13, 14, 16-22, 25.) 

However, Mayweather-Brown was not always receptive to Yoder’s attempts to help 
68

him with his behavioral issues. (Id.) Nonetheless, the record in this case establishes that

Yoder continued to advocate for Mayweather-Brown’s well-being and acted reasonably 

to ensure his safety during this period. (Id.) 

When Mayweather-Brown returned to Elkhart Jail in May 2015, Yoder was once 

again involved in his mental health care on nearly a daily basis. (ECF 212-7 at ¶¶ 24-49, 

51, 53-57.) He provided Mayweather-Brown with extensive counseling services, 

monitored his destructive behavior, and followed Dr. Mathew’s “hands-off” treatment 

plan. (Id.) However, Mayweather-Brown continued to threaten suicide, was extremely 

manipulative, and placed himself, other inmates, mental health staff, and jail officers in 

danger. (Id. at 59.) In January 2016, after Mayweather-Brown left the Elkhart Jail, Yoder 

noted that he had been one of the most difficult inmates to treat. (Id.) He reiterated that 

Mayweather-Brown had used threats of suicide and attempts at self-harm to get things 

he wanted, including minor things such as turning on a television. (Id.) He noted that 

staff “had to balance that knowledge with the risk that he might actually harm himself 

and decide when it was appropriate to place him on suicide watch, knowing that being 

placed on suicide watch made Mr. Mayweather-Brown escalate his behavior.” (Id.)

In sum, Yoder provided Mayweather-Brown with extensive counseling, 

monitored his behavior, and assisted Dr. Mathew in implementing the “hands-off” 

treatment plan. Notably, Yoder also sought to obtain additional psychiatric care for 

Mayweather-Brown by requesting that he be placed in a local hospital. Here, 

Mayweather-Brown has produced no evidence to show that Yoder’s mental health care 

was objectively unreasonable. Given the record in this case, this court finds that no 
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reasonable fact finder could conclude that Yoder’s mental health care was objectively 

unreasonable. 

Robin Yohn

Mayweather-Brown next asserts that Robin Yohn violated his Fourteenth 

Amendment rights because, as a nurse, she knew the risks associated with failing to get 

him adequate mental health treatment. (ECF 232-1 at 33-34.) He claims she participated 

in the March 21, 2014, meeting where it was established that he needed treatment at an 

off-site state psychiatric facility where they were equipped to manage his behavior. (Id.

at 34.) However, she failed to ensure that his civil commitment papers were properly 

filed so that he would have access to the necessary mental health treatment. (Id.) 

Yohn worked as a Health Services Administrator for CCS at the Elkhart Jail 

during the relevant time period. (ECF 212-6 at ¶ 3.) In this role, Yohn provided 

administrative services such as ordering medical supplies, hiring medical staff, and 

maintaining nursing staff schedules. (Id. at ¶ 4.) She did not prescribe medications, 

establish treatment plans, place inmates on self-harm or suicide observation, or decide 

what items that inmates could have in their cells. (Id. at ¶¶ 4, 5.) Put simply, Yohn 

served as the office administrator of the medical department at the jail. (Id.) While Yohn 

is a registered nurse, she was never personally involved in Mayweather-Brown’s dayto-day medical assessment or treatment. (Id. at ¶ 4.)

Yohn’s only involvement with Mayweather-Brown, besides occasionally being 

present when medical or mental health personnel were providing care, was attending 

staff meetings to discuss the efficacy of his treatment plan. (ECF 212-6 at ¶ 5.) She 
70

attended these meetings not as a healthcare provider or a policy maker, but as an 

administrative liaison between jail officers and medical staff. (Id.) Yohn’s role in these 

meetings was to understand the resources required for Mayweather-Brown’s care so 

that she could schedule nursing staff and allocate resources appropriately. (Id.) She did 

not develop his treatment plan and did not act in her role as a registered nurse to carry 

out the treatment plan. (Id.) In essence, Yohn simply managed the logistics of providing 

care to Mayweather-Brown, and all other inmates at the Elkhart Jail. (Id.)

In his deposition, Mayweather-Brown explained that he sued Yohn because “she 

was the one in charge of medical” and she was present during meetings to discuss his 

care. (ECF 212-4 at 34:12-19.) As stated, however, Yohn was only “in charge of medical” 

to the extent that she scheduled nursing staff, ordered supplies, and responded to 

grievances regarding medical issues. (ECF 212-7 at ¶ 4.) She did not treat inmates or 

manage treatment plans created by the medical providers. (Id. at ¶¶ 4, 5.) Yohn did not 

violate Mayweather-Brown’s constitutional rights simply by being the “head of 

medical.” She also did not provide direct care to Mayweather-Brown, nor did she direct 

the care that medical and mental health staff, or jail staff provided to him. (Id. at ¶ 5.) 

Furthermore, Yohn testified that when she became aware that Mayweather-Brown had 

either harmed himself or was going to harm himself, she notified the appropriate 

medical and mental health staff so they could address the issue. (Id.) Accordingly, 

because Yohn was not involved in Mayweather-Brown’ medical care, no reasonable fact 

finder could conclude that she violated his constitutional rights under the Fourteenth 

Amendment.
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Steffany Bigler

Mayweather-Brown moves for summary judgment against Lieutenant Bigler 

asserting that, by failing to provide him with adequate medical care, she exposed him to 

grave risks of harm, injury, and even death. (ECF 232-1 at 14.) He claims that she acted 

in “concert as a governing body making decisions as a group and instructed everyone 

under them to stick to the treatment plan.” (Id. at 25.) Mayweather-Brown asserts that 

Bigler routinely sent memos to staff instructing them on how to treat him and ordered 

staff to interfere or obstruct his mental healthcare. (Id.) He claims that Bigler recklessly 

instructed staff to separate his behavior from his mental health condition. (Id. at 26.)

Mayweather-Brown also asserts that Bigler failed to respond to a court order directing 

her to provide psychiatric care for him and she did not respond to his grievance about 

his attempts at self-harm. (Id. at 27.) However, Bigler testified in her affidavit as follows:

“I never received a court order regarding psychiatric care of Mayweather.” (Id. at ¶ 12.)

He further asserts that Bigler instituted Dr. Mathew’s “hands off” treatment plan as a 

form of administrative segregation to punish him. (Id. at 25.)

The court’s review of the record shows that there is no evidence to suggest that 

Bigler or CCS medical staff failed to provide Mayweather-Brown with appropriate

medical and mental health care from March 2014 through June 2014. First, as discussed, 

the record in this case shows that Mayweather-Brown received an unusually high 

amount of personalized treatment from the medical and mental health staff at the 

Elkhart Jail. Next, Bigler sought to protect his well-being by increasing MayweatherBrown’s suicide watch level and being restrained as the need arose. (ECF 212-1 at ¶ 15; 
72

212-1 at 10.) And during the time he was on suicide watch, he was regularly monitored 

by jail officers. (Id. at ¶ 18.) Bigler also did not issue an order to interfere with or 

obstruct Mayweather-Brown’s access to healthcare, nor did she issue an order to jail 

officers to ignore his serious healthcare needs. (Id. at ¶5.) However, she did instruct jail 

officers not to use force against Mayweather-Brown unless they had to gain compliance 

or protect him from serious bodily harm or injury. (Id. at ¶ 6.) Bigler also instructed jail 

officers to contact CCS so that any injuries he sustained from his mental health issues 

could be documented and evaluated. (Id. at ¶ 7.) Thus, Bigler took steps to implement 

appropriate measures to safeguard Mayweather-Brown from committing suicide and to 

protect him.

Mayweather-Brown has also asserted several propositions that are not supported 

by the record. For example, Bigler did not issue an order or instructions to jail officers 

concerning Mayweather-Brown’s medical or mental health treatment. (ECF 212-1 at ¶

11.) Nor did she receive a court order regarding his psychiatric care. (Id. at ¶ 12.) Bigler 

was also not aware that Mayweather-Brown filed a grievance at the jail about his 

attempts to harm and that grievance was ignored. (Id. at ¶ 18.) While MayweatherBrown makes an issue about the fact that Bigler informed jail officers that his “mental 

health status and disciplinary status are not the same and do not depend on each 

other,” that fact is irrelevant to whether he received constitutionally adequate medical 

care while he was housed at the Elkhart Jail. (ECF 212-1 at ¶ 8; 212-1 at 6.) 

In sum, Mayweather-Brown was a threat to his own safety and that of jail staff. 

He engaged in altercations with jail officers and injured some of them. Mayweather-
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Brown also caused extensive damage to the Elkhart Jail and made multiple attempts at 

suicide. He routinely refused medical treatment, sometimes violently. Because of his 

behavior, on June 2, 2014, the Sheriff’s Department requested and obtained a court 

order from the Elkhart Superior Court under Cause No. 20D02-1402-FC-48 to transfer 

Mayweather-Brown to the IDOC for safekeeping. (ECF 212-2 at ¶ 8; 212-2 at 40.) Given

Bigler’s extensive role in managing and monitoring Mayweather-Brown’s medical and 

mental health care during this period, no reasonable fact finder could find that the care 

was objectively unreasonable. 

Furthermore, after Mayweather-Brown returned to the jail in May 2015 and until 

he left in January 2016, Bigler was entitled to rely on the medical and mental health staff 

to provide adequate and appropriate care to him. In other words, non-medical staff 

who rely on medical experts are “entitled to relegate to the prison’s medical staff the 

provision of good medical care.” Burks v. Raemisch, 555 F.3d 592, 595 (7th Cir. 2009); 

Johnson v. Doughty, 433 F.3d 1001, 1012 (7th Cir. 2006). That is what happened in this 

case. Bigler reasonably relied on the CCS medical staff to make decisions regarding 

Mayweather-Brown’s medical and mental healthcare issues. (ECF 212-1 at ¶ 10.) As 

discussed, Dr. Mathew worked on CCS’s staff and crafted the “hands-off” treatment 

plan which was specifically tailored to treat Mayweather-Brown’s mental health issues 

and protect him from self-harm. Yoder along with other medical and mental health staff 

worked with Mayweather-Brown to combat his mental health issues by providing him 

with counseling, medication, suicide observation to keep him save, and by addressing a

myriad of daily issues. Given the substantial medical record detailing the personalized 
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and daily treatment Mayweather-Brown received from the medical and mental health 

staff, Bigler’s reliance on the judgment of these trained medical professionals cannot be 

viewed as being objectively unreasonable. Therefore, no reasonable fact finder could 

find that Bigler violated Mayweather-Brown’s Fourteenth Amendment rights. 

John Perry

Mayweather-Brown moves for summary judgment against Captain Perry

asserting he provided him with constitutionally inadequate medical care because he 

“assisted, condoned, and consented” to Dr. Mathew’s “hands-off” treatment plan. (ECF 

232-1 at 18.) He next complains that Perry violated IDOC policy by ignoring the 

provision of the policy that prohibits the creation and implementation of the “handsoff” treatment plan—a plan that Mayweather-Brown believes constitutes cruel and 

unusual punishment. (Id. at 20.) Furthermore, Mayweather-Brown claims that Perry’s 

job duties that included “accumulat[ing] information and reports for future legal 

defense” led the Defendants to “falsify medical documents and transfer paperwork.” 

(Id. at 22.)

As discussed, Mayweather-Brown was provided with constitutionally adequate 

medical and mental health care while he was housed at the Elkhart Jail. Like Bigler, 

Perry was entitled to rely on the professional judgment of the medical and mental 

health staff who treated Mayweather-Brown. Burks, 555 F.3d at 595. To the extent, 

Mayweather-Brown claims Perry violated prison policy by condoning Dr. Mathew’s 

treatment plan, failure to follow policy is not a constitutional violation. Scott v. Edinburg, 

346 F.3d 752, 760 (7th Cir. 2003) (“However, 42 U.S.C. § 1983 protects plaintiffs from 
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constitutional violations, not violations of state laws or, in this case, departmental 

regulations and police practices.”). Furthermore, Mayweather-Brown has produced no 

evidence to support his contention that Perry or the Defendants’ falsified his medical 

records and transfer paperwork. Therefore, there is no evidence for this court to 

conclude that Perry’s conduct was objectively unreasonable given the facts in this case.

In conclusion, Mayweather-Brown’s motion for summary judgment is denied as 

to inadequate medical care claim brought pursuant to the Fourteenth Amendment and 

the Defendants’ motions for summary judgment are granted as to this claim.

Conditions of Confinement Claim

In moving for summary judgment, Mayweather-Brown also asserts that Perry, 

Bigler, and Yoder failed to provide him with appropriate conditions of confinement, 

including adequate clothing, bedding, and heat while housed at the Elkhart Jail in 

violation of his Fourteenth Amendment rights. (ECF 202; 232.) He specifically argues 

that these defendants were deliberately indifferent to his needs and subjected him to a 

substantial risk of harm by denying him appropriate accommodations during those 

periods he was on suicide watch and suffering from his mental illness. On the other 

hand, the Defendants claim they were not deliberately indifferent to MayweatherBrown’s confinement needs and sought to protect him by denying him access to 

blankets, clothing, and mattresses because he often used these items to attempt suicide. 

(ECF 211 at 12; 214 at 15.) Here, the Defendants explain that, because they relied on the 

advice of the medical and mental health staff, their conduct in removing items from 
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Mayweather-Brown that he could use to commit suicide does not constitute deliberate 

indifference on their part. (ECF 214 at 15.)

On August 12, 2019, the Seventh Circuit in Hardeman v. Curran, 933 F.3d 816 (7th 

Cir. 2019) held that “Kingsley’s objective inquiry applies to all Fourteenth Amendment 

conditions-of-confinement claims brought by pretrial detainees.” 933 F.3d at 823. 

Because the standard for conditions of confinement claims has changed, the court 

denies the parties’ motions (ECF 200; 210; 213) with respect to this issue with leave to 

refile a summary judgment motion addressing only the “objective unreasonableness” 

standard articulated in Hardeman.6

Therefore, the court:

(1) DENIES Quintin J. Mayweather-Brown’s Motion to Strike (ECF 271);

(2) DENIES Quintin J. Mayweather-Brown’s Motion for a Preliminary Ruling on 

the Admissibility of Evidence (ECF 277);

(3) DENIES Quintin J. Mayweather-Brown’s Motion for the Taking of Judicial 

Notice of Law (ECF 278);

(4) DENIES Quintin J. Mayweather-Brown’s Motion to Rule on the Motion for 

the Taking of Judicial Notice of Law (ECF 279);

(5) DENIES Quintin J. Mayweather-Brown’s Motion for Preliminary Ruling on 

the Admissibility of Newly Discovered Evidence (ECF 280);

 

6 The parties may, if they chose, incorporate the court’s facts in lieu of a separate Statement of 

Material Facts. See N.D. Ind. L.R. 56-1(a).
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(6) DENIES Quintin J. Mayweather-Brown’s Motion for Admissibility of 

Evidence and Motion for Preliminary Ruling on Newly Obtained Evidence (ECF 287);

and

(7) DENIES Quintin J. Mayweather-Brown’s Motion for the Taking of Judicial 

Notice of Adjudicative Facts (ECF 289).

(8) DENIES Quintin J. Mayweather-Brown’s Motion for Summary Judgment 

(ECF 200) on the issue of whether he received constitutionally adequate medical care 

while housed at the Elkhart Jail in violation of the Fourteenth Amendment;

(9) GRANTS Lieutenant Steffany Bigler, Captain John Perry, Dr. Josh Mathew, 

Robin Yohn, and Gary Yoder’s Motions for Summary Judgment (ECF 210; 213) on the 

issue of whether Quintin J. Mayweather-Brown received constitutionally adequate 

medical care while housed at the Elkhart Jail in violation of the Fourteenth Amendment;

(10) DENIES Mayweather-Brown’s Motion for Summary Judgment (ECF 200) on 

the conditions of confinement issue with leave to refile a summary judgment motion on 

this issue only utilizing the “objective unreasonableness” standard for Fourteenth 

Amendment claims pertaining to conditions of confinement issues as articulated in 

Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019) by October 31, 2019; and

(11) DENIES Lieutenant Steffany Bigler, Captain John Perry, Dr. Josh Mathew, 

Robbin Yohn, and Gary Yoder’s Motions For Summary Judgment (ECF 210; 213) on the 

conditions of confinement issue with leave to refile a motion for summary judgment on 

this issue only utilizing the “objective unreasonableness” standard for Fourteenth 
78

Amendment claims pertaining to conditions of confinement issues as articulated in 

Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019) by October 31, 2019.

SO ORDERED on September 30, 2019

 /s/ JON E. DEGUILIO

JUDGE

UNITED STATES DISTRICT COURT