Barber v. Tharp

CourtDistrict Court, S.D. Illinois
DecidedDecember 13, 2021
Docket3:21-cv-01003
StatusUnknown

This text of Barber v. Tharp (Barber v. Tharp) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barber v. Tharp, (S.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

EARL BARBER, #99256 ) ) Plaintiff, ) vs. ) Case No. 3:21-cv-01003-SMY ) KRISTOPHER THARP, and ) PAUL SARHAGE, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Earl Barber and 12 other individuals filed the instant lawsuit pursuant to 42 U.S.C. § 1983 for alleged deprivations of their constitutional rights at Madison County Jail. The claims were severed into thirteen separate actions. (Doc. 1). This case is now before the Court for preliminary review of the Complaint (Doc. 2) on Barber’s claim under 28 U.S.C. § 1915A. Any portion of the Complaint that is legally frivolous, malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 2): Plaintiff’s entire cell block at Madison County Jail (“Jail”) was placed on lockdown on July 29, 2021 when Lieutenant Sarhage smelled smoke. Without investigating the matter, issuing any disciplinary tickets, or conducting a disciplinary hearing, all detainees in the block were punished with a thirty-day lockdown and commissary restriction. For some of this time, inmates could not purchase stamps and other supplies. Two weeks before the incident, Captain Tharp issued a memorandum to notify detainees that staff recently observed inmates attempting to start “small fires.” Tharp made it clear that this conduct would not be tolerated. He instructed detainees to report such incidents immediately and warned them that failing to do so would result in a “non-negotiable thirty (30) day lockdown of the block where the incident occurs,” as well as a loss of commissary privileges for the same time period. He added that this thirty-day punishment was only a starting point and could be extended.

When several inmates filed grievances to complain about their punishment in July and August 2021, Tharp instructed detainees not to “waste my time or yours writing me telling me how unfair things are [because] [t]here will be no discussion on the matter.” Tharp emphasized that his top priority was the safety of the inmates. Based on the allegations in the Complaint, the Court designates the following claims in this pro se action: Count 1: Fourteenth Amendment claim against Defendants Tharp and Sarhage for depriving Plaintiff of a protected liberty interest without due process of law by punishing him with a thirty-day lockdown and commissary restriction after Sarhage smelled smoke in the cell block on or around July 29, 2021.

Count 2: First and/or Fourteenth Amendment claim against Defendants Tharp and Sarhage for depriving Plaintiff of access to the courts by denying him stamps for use in contacting an attorney beginning on or around July 29, 2021.

Any claim that is mentioned in the Complaint but not addressed in this Order is dismissed without prejudice as inadequately pled under the Twombly pleading standard. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim that is plausible on its face.”). Discussion Count 1 A Fourteenth Amendment due process claim arises when the state deprives a person of a constitutionally protected interest in “life, liberty, or property” without due process of law. Zinermon v. Burch, 494 U.S. 113, 125 (1990). Any “nontrivial punishment of a person not yet convicted” is a sufficient deprivation of liberty to give rise to due process protections. See Holly v. Woolfolk, 415 F.3d 678, 679-80 (7th Cir. 2005) (collecting cases). A pretrial detainee cannot be placed in segregation or lockdown segregation as punishment for a disciplinary infraction

without notice and an opportunity to be heard; due process requires no less. Rapier v. Harris, 172 F.3d 999, 1004-05 (7th Cir. 1999). A person who is lawfully detained in pretrial confinement is nevertheless subject to certain restrictions on his liberty. See Rapier, 172 F.3d at 1003. In particular, the state may take reasonable measures to effectuate pretrial detention, and this includes steps necessary to maintain safety and security at the facility. Id. As long as these measures are reasonably related to the orderly management of the facility, they are not considered punishment for the crime the detainee is charged with committing. Id. Tharp’s memo refers to small fires that inmates were caught starting in early July 2021, and it threatens consequences for failing to report future attempts to start fires. Plaintiff’s

Complaint characterizes the lockdown and commissary restrictions as “punishment” for the smell of smoke on July 29, 2021. Given that his placement in lockdown and commissary restrictions lasted thirty days, he may have been subject to punishment. And, according to Plaintiff, he received no due process protections, such as notice or a hearing, before or after the punishment occurred. Plaintiff has stated a colorable claim, and Count 1 will be allowed to proceed against both defendants.1

1 This analysis hinges on Plaintiff’s classification as a pretrial detainee when the punishment occurred. If further factual development reveals that he was a convicted prisoner at the time, the standard set forth in Hardaway v. Meyerhoff, 734 F.3d 740 (7th Cir. 2013), and Marion v. Columbia Corr. Inst., 559 F.3d 693, 697 (7th Cir. 2009), governs this claim and may warrant dismissal of Count 1. Count 2 Convicted persons and pretrial detainees have a fundamental right of meaningful access to the courts. Bounds v. Smith, 430 U.S. 817 (1977) (convicted persons); Casteel v. Pieschek, 3 F.3d 1050, 1053 (7th Cir. 1993) (pretrial detainees). A claim for denial of access to the courts involves

two elements. Smith v. Shawnee Library Sys., 60 F.3d 317 (7th Cir. 1995); Jenkins v. Lane, 977 F.2d 266, 268 (7th Cir. 1992). First, the plaintiff must show that officials failed “to assist in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.” Jenkins, 977 F.2d at 268 (quoting Bounds, 430 U.S. at 828). Second, the plaintiff must show “some quantum of detriment caused by the challenged conduct of state officials resulting in the interruption and/or delay of plaintiff’s pending or contemplated litigation.” Id.; Alston v. DeBruyn, 13 F.3d 1036, 1041 (7th Cir. 1994). Plaintiff’s allegations only address the first element of this claim. He complains of the denial of access to stamps beginning July 29, 2021.

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Related

Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Byron Alston v. H. Christian Debruyn
13 F.3d 1036 (Seventh Circuit, 1994)
Christopher Holly v. D. Woolfolk
415 F.3d 678 (Seventh Circuit, 2005)
Marion v. Columbia Correctional Institution
559 F.3d 693 (Seventh Circuit, 2009)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)
Maurice Hardaway v. Brett Meyerhoff
734 F.3d 740 (Seventh Circuit, 2013)
Casteel v. Pieschek
3 F.3d 1050 (Seventh Circuit, 1993)

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Barber v. Tharp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barber-v-tharp-ilsd-2021.