UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF WISCONSIN
________________________________________________________________________
KARI SUNDSTROM and ANDREA
FIELDS,
Plaintiffs,
v.
Case No. ___________
MATTHEW J. FRANK, Secretary of the
Wisconsin Department of Corrections;
JUDY P. SMITH, Warden of the Oshkosh
Correctional Institution; THOMAS
EDWARDS, Manager of the Medical
Services Unit at the Oshkosh Correctional
Institution; JAMES GREER, Director of the
Wisconsin Department of Corrections
Bureau of Health Services; and ROMAN
KAPLAN, M.D., medical doctor at the
Oshkosh Correctional Institution, in their
official capacities,
Defendants.
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COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
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1.
Kari Sundstrom and Andrea Fields (collectively, “Plaintiffs”), by their attorneys,
for their Complaint against Matthew J. Frank, Judy P. Smith, Thomas Edwards, James Greer,
and Roman Kaplan M.D., in their official capacities (collectively, “Defendants”), allege as
follows:
NATURE OF THE ACTION
2.
This Complaint asserts a civil rights action pursuant to 42 U.S.C. § 1983 for
declaratory and injunctive relief to redress Defendants’ violations of Plaintiffs’ rights under the
Eighth and Fourteenth Amendments to the United States Constitution. Defendants have violated
the Constitution by enforcing 2005 Wisconsin Act 105 and abruptly terminating and depriving
Plaintiffs of medical treatment for Plaintiffs’ serious health conditions, with no exercise
whatsoever of individualized medical judgment and in contrast to the treatment Defendants
provide to other similarly situated inmates at Wisconsin Department of Corrections (“DOC”)
facilities. Plaintiffs seek an end to those actions of Defendants that violate Plaintiffs’ right to
equal protection and their right to be free from cruel and unusual puni