Ausmas v. Jeffreys

2021 IL App (4th) 200521-U
CourtAppellate Court of Illinois
DecidedJune 11, 2021
Docket4-20-0521
StatusUnpublished

This text of 2021 IL App (4th) 200521-U (Ausmas v. Jeffreys) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ausmas v. Jeffreys, 2021 IL App (4th) 200521-U (Ill. Ct. App. 2021).

Opinion

NOTICE 2021 IL App (4th) 200521-U This Order was filed under FILED Supreme Court Rule 23 and is NO. 4-20-0521 June 11, 2021 not precedent except in the Carla Bender limited circumstances allowed 4th District Appellate IN THE APPELLATE COURT Court, IL under Rule 23(e)(1).

OF ILLINOIS

FOURTH DISTRICT

RICHARD AUSMUS, ) Appeal from the Petitioner-Appellant, ) Circuit Court of v. ) Logan County ROB JEFFREYS, in His Official Capacity as Director of ) No. 20MR88 Corrections, and EMILY RUSKIN, in Her Official ) Capacity as the Warden of Lincoln Correctional Center, ) Respondents-Appellees. ) Honorable ) Thomas W. Funk, ) Judge Presiding.

JUSTICE TURNER delivered the judgment of the court. Justices Cavanagh and Holder White concurred in the judgment.

ORDER

¶1 Held: The circuit court’s dismissal of petitioner’s petition for an injunction was proper.

¶2 In June 2020, petitioner, Richard Ausmus, filed a pro se petition for an injunction

against respondents, Rob Jeffreys, in his official capacity as Director of Corrections, and Emily

Ruskin, in her official capacity as warden of the Lincoln Correctional Center. In his petition,

petitioner sought an injunction to compel respondents to (1) reduce the population of Lincoln

Correctional Center by half, (2) apply good conduct credit sufficient to allow for his release,

(3) allow him access to fresh air as needed, and (4) maintain the ventilation system in

compliance with standards set by the United States Occupational Safety and Health

Administration (OSHA). He contended respondents acted with deliberate indifference to the

health risks possessed by the COVID-19 pandemic in violation of the eighth amendment (U.S. Const., amend. VIII). In September 2020, respondent Jeffreys filed what was essentially a

combined motion to dismiss under section 2-619.1 of the Code of Civil Procedure (Procedure

Code) (735 ILCS 5/2-619.1 (West 2018)) and a supporting memorandum, asserting petitioner

failed to state a cause of action and failed to exhaust his administrative remedies at the

institutional level. After a September 2020 hearing, the Logan County circuit court dismissed

with prejudice petitioner’s petition.

¶3 Petitioner appeals pro se, asserting the circuit court erred by dismissing his

petition because (1) the doctrine of exhaustion of remedies did not apply and (2) he did specify

he was seeking relief under the eighth amendment. We affirm.

¶4 I. BACKGROUND

¶5 On March 28, 2020, petitioner, an inmate at the Lincoln Correctional Center, filed

a grievance alleging deliberate indifference and an eighth amendment violation. Petitioner stated

he was 54 years old with asthma, high cholesterol, and prostate issues. He noted the governor

had issued a stay-at-home order due to the COVID-19 pandemic with limitations on businesses

and social gatherings. Despite the need for social distancing, petitioner was forced to live on a

wing that had 5 dorms with 20 inmates in each dorm. As such, 100 inmates shared the same

restroom, telephones, kiosk machines, and showers. Petitioner noted he was also being forced to

walk to the inmate dining hall for meals and the inmates who worked there were from different

housing units, exposing petitioner to even more people. Petitioner asserted respondents had an

obligation to protect him and other inmates in the facility from the risk of COVID-19. He

requested the dorms be limited to 10 inmates and the inmates not be allowed to leave the wing.

Additionally, petitioner requested $20,000 or release from custody for the eighth amendment

violation.

-2- ¶6 In June 2020, petitioner filed his petition for a “motion for emergency/mandatory

and/or preventive injunction.” In his petition, petitioner asserted he received a March 30, 2020,

counseling summary in response to his grievance, which noted petitioner’s grievance could not

be resolved at the facility and directed petitioner to mail his grievance to the administrative

review board. Petitioner forwarded his grievance to the administrative review board on April 3,

2020, but his grievance remained unresolved. He further alleged respondents were subjecting

him to cruel and unusual punishment by their deliberate indifference to the serious threat to

human life posed by COVID-19. Petitioner noted the lack of social distancing, an inadequate

ventilation system, his inability to access fresh air, and the housing of 100 inmates per wing in a

small area. He sought an injunction to compel respondents to (1) reduce the population of

Lincoln Correctional Center by half, (2) apply good conduct credit sufficient to allow for his

release, (3) allow him access to fresh air as needed, and (4) maintain the ventilation system in

compliance with OSHA standards.

¶7 In September 2020, respondent Jeffreys filed a motion to dismiss petitioner’s

petition because petitioner failed to (1) exhaust the administrative remedies available to him and

(2) state a claim for deliberate indifference under the eighth amendment. Petitioner filed a

response to the motion, arguing he was not required to exhaust administrative remedies because

(1) only the federal Prison Litigation Reform Act of 1995 (42 U.S.C. § 1997e (2018)) required

exhaustion of remedies and it did not apply to state court actions, (2) petitioner made a timely

reservation of rights under the Uniform Commercial Code (810 ILCS 5/1-101 et seq. (West

2018)), and (3) an inmate alleging a deliberate indifference claim was not required to wait until

the harm occurred.

¶8 On September 17, 2020, the circuit court held a telephone hearing on respondent

-3- Jeffreys’s motion to dismiss. A report of proceedings for that hearing is not included in the

record on appeal. At the end of the hearing, the court took the matter under advisement. On

October 1, 2020, the court entered a written order dismissing with prejudice petitioner’s petition

in its entirety. The court treated the petition as one seeking mandamus relief. It found petitioner

failed to demonstrate his administrative remedies had been exhausted. The court also concluded

petitioner had failed to allege sufficient facts showing a deliberate indifference to his condition.

¶9 On October 8, 2020, petitioner filed a timely notice of appeal from the dismissal

of his petition in sufficient compliance with Illinois Supreme Court Rule 303 (eff. July 1, 2017).

Thus, this court has jurisdiction of petitioner’s appeal under Illinois Supreme Court Rule 301

(eff. Feb. 1, 1994).

¶ 10 II. ANALYSIS

¶ 11 In this case, petitioner appeals from the circuit court’s dismissal of his petition

seeking an injunction. Regardless of whether the circuit court’s dismissal of petitioner’s petition

was under section 2-615 of the Procedure Code (735 ILCS 5/2-615 (West 2018)) or section

2-619 of the Procedure Code (735 ILCS 5/2-619 (West 2018)), or a combination of both sections

pursuant to section 2-619.1, this court’s standard of review is the same. Jane Doe-3 ex rel. Julie

Doe-3 v. White, 409 Ill. App. 3d 1087, 1092, 951 N.E.2d 216, 223 (2011).

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2021 IL App (4th) 200521-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ausmas-v-jeffreys-illappct-2021.