Does the intentional infliction of severe emotional distress, by triggering PTSD symptoms, that caused psychological harm, rise to a level that is cognizable under the Eighth Amendment?

QUESTIONS PRESENTED 1. Does the intentional infliction of severe emotional distress, by triggering PTSD symptoms, that caused psychological harm, rise to a level that is cognizable under the Eighth Amendment? 2. Did the United States Court of Appeals for the Seventh Circuit have jurisdiction on the question of Qualified Immunity as a matter of law when the liability of the actor’s intent is a qualifying element of the cause giving rise to the Constitutional Violation? : 3. Is it well-established law that a correctional officer violates the rights of an inmate when carrying out their duties in a way that goes beyond what would otherwise be penologically justified and to intentionally inflict severe emotional distress causing psychological harm? ; 4. Does a correctional officer have a duty to respond to the self-reported medical or psychological symptoms of an inmate in their care as they relate to the inmate’s safety? ; : 5. Does Qualified Immunity protect non-medical staff from the wanton infliction of psychological pain when the prohibition is not stated in an inmate’s medical treatment plan? PARTIES ; 1. Jeffrey Leiser (Leiser) is an inmate in the custody of the Wisconsin Department of Corrections (““WDOC”) housed at the Stanley Correctional Institution (“SCI”) at the time relevant to the claims in this matter. (Complaint, R1!:1) 2. At all times relevant to this matter, Karen Kloth (Kloth) was employed by WDOC as a Correctional Sergeant at SCI, whose responsibilities included, but were not limited to, supporting unit staff, maintaining security of the institution, safety of inmates on the unit and performing general tasks within the various housing units. (Kloth Declaration, R1:24 at §[{] 2-3.) 3. At all times relevant to this matter, Paula Stoudt (Stoudt) was employed by ; WDOC as a Corrections Unit Supervisor (Unit Manager) at SCI in Unit 1 with the responsibilities, under the general supervision of the warden/deputy warden, for the security, treatment, and general living conditions of all inmates assigned ' to the units. (Stoudt Declaration, R1:25 at {2 -3.) 4. At the times relevant to this complaint, Reed Richardson (Richardson) was employed by WDOC as the Warden at SCI and is responsible for the overall . administration and operation of SCI. (Richardson Declaration, R1:26 at {{/2-3.) | References to the United States District Court for the Western District of Wisconsin Record identified as “R1”; references to the United States Court of Appeals for the Seventh Circuit identified as “R2.” : ii