Beck v. Unknown Sangamon County Sheriff's Dept Employees

CourtDistrict Court, C.D. Illinois
DecidedApril 6, 2022
Docket3:22-cv-03036
StatusUnknown

This text of Beck v. Unknown Sangamon County Sheriff's Dept Employees (Beck v. Unknown Sangamon County Sheriff's Dept Employees) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beck v. Unknown Sangamon County Sheriff's Dept Employees, (C.D. Ill. 2022).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS

JOHN W BECK, ) ) Plaintiff, ) v. ) Case No. 22-cv-3036-MMM ) UNKNOWN SANGAMON COUNTY ) SHERIFF’S DEPT EMPLOYEES, et al., ) ) Defendants. )

MERIT REVIEW

Plaintiff, proceeding pro se, files a complaint under 42 U.S.C. § 1983 alleging deliberate indifference to his serious medical needs at the Sangamon County Jail (“Jail”). This case is before the Court for a merit review pursuant to 28 U.S.C. § 1915A. In reviewing the complaint, the Court accepts the factual allegations as true, liberally construing them in Plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649-51 (7th Cir. 2013). However, conclusory statements and labels are insufficient. Enough facts must be provided to “state a claim for relief that is plausible on its face.” Alexander v. United States, 721 F.3d 418, 422 (7th Cir. 2013) (citation and internal quotation marks omitted). While the pleading standard does not require “detailed factual allegations,” it requires “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Wilson v. Ryker, 451 Fed. Appx. 588, 589 (7th Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). FACTS Plaintiff, who is a pretrial detainee, alleges that an unidentified law enforcement officer shot him with a taser on or about April 20, 2021, in Springfield, Illinois. After Plaintiff was handcuffed, an unknown law enforcement officer yanked the taser wires from Plaintiff’s leg and placed him in a police vehicle. On the way to the Jail, Plaintiff informed two Springfield police officers that it felt like he was bleeding and there was something wrong with his leg. The officers told Plaintiff to “shut up.” The unknown officer who shot Plaintiff with the taser escorted him into the Jail. Plaintiff told the officer and multiple Jail deputies about his leg. When the deputies searched Plaintiff, they discovered that he was bleeding from a wound on his left leg. Plaintiff again asked for medical

attention and was told to “shut the ‘F’ up.” (Doc. 1 at 6). Plaintiff was placed in a holding cell in the booking area of the Jail. His leg continued to “bleed quite badly.” Id. He requested medical attention each time a deputy came near his cell, but they ignored his requests. That night, Plaintiff was removed from his cell and taken to a room with several unknown law enforcement officers. He told them about his leg and asked for medical treatment. The officers told Plaintiff he would receive medical attention if he cooperated and answered their questions. Plaintiff’s clothes were taken as evidence, and the lower left leg of his pants was soaked in blood. After removing his pants, an unknown jail deputy saw that Plaintiff was bleeding from what looked like a bullet hole in his left leg. Plaintiff was given jail clothes and returned to the booking area.

Plaintiff never saw medical staff during his week-long stay at the Jail. On or about April 27, 2021, Plaintiff was transported to the Livingston County Jail. He informed Officer Lynn that he needed medical attention. A nurse examined his leg and prescribed antibiotics and pain medication. Plaintiff’s leg was x-rayed a few weeks later. The x-ray revealed a taser dart lodged in Plaintiff’s leg. Plaintiff underwent surgery for the removal of the taser dart at St. James Hospital in Pontiac, Illinois on June 14, 2021. Plaintiff brings his complaint against Unknown Sangamon County Sheriff’s Dept Employees, Unknown Sangamon County Jail Medical Staff, Unknown Sangamon County Jail Employees, and Unknown Springfield, Illinois City Police Employees. Plaintiff requests compensatory and punitive damages. ANALYSIS

It is well established that deliberate indifference to the serious medical needs of prisoners violates the Eighth Amendment. Snipes v DeTella, 95 F.3d 586, 590 (7th Cir 1996) (citing Estelle v. Gamble, 429 U.S. 97, 104 (1976)). In the case of pretrial detainees, actions for deliberate indifference arise under the Due Process Clause of the Fourteenth Amendment, rather than the Eighth Amendment, but the same standard applies. Zentmyer v. Kendall County, Ill., 220 F.3d 805, 810 (7th Cir. 2000). A plaintiff alleging deliberate indifference to a serious medical need must show (1) that the defendant knew of the serious medical need, and (2) disregarded that need. Collignon v. Milwaukee County, 163 F.3d 982, 989 (7th Cir 1998) (citing Farmer v. Brennan, 511 U.S. 825, 837 (1994)). Under the Fourteenth Amendment standard, a pretrial detainee must

establish that the defendant’s conduct was objectively unreasonable, not that defendant was subjectively aware that it was unreasonable. Miranda v. County of Lake, 900 F.3d 335, 352 (7th Cir. 2018) (citing Kingsley v. Hendrickson, 576 U.S. 389 (2015)). In other words, that defendant “knew, or should have known, that the condition posed an excessive risk to health or safety” and “failed to act with reasonable care to mitigate the risk.” Darnell v. Pineiro, 849 F.3d 17, 35 (2d Cir. 2017). This standard is higher than that required to prove negligence, or even gross negligence and is “akin to reckless disregard.” Miranda, 900 F.3d at 353 (quoting Castro v. County of Los Angeles, 833 F.3d 1060, 1071 (9th Cir. 2016)). Here, Plaintiff states enough at the pleadings stage to allege deliberate indifference to his serious medical needs; however, Plaintiff has not identified any of these defendants with

particularity. They cannot be served with the lawsuit at this time. Where a prisoner's complaint states specific allegations describing conduct of individual defendants sufficient to raise a constitutional claim, but the names of those defendants are not known, the prisoner should have the opportunity to engage in limited discovery to ascertain the identity of those defendants. Rodriguez v. Plymouth Ambulance Service, 577 F.3d 816, 832 (7th Cir. 2009). “Depending on the particular circumstances of the case, the court may assist the plaintiff by providing counsel for the

limited purpose of amending the complaint; by ordering the named defendants to disclose the identities of unnamed officials involved; by allowing the case to proceed to discovery against high- level administrators with the expectation that they will identify the officials personally responsible; by dismissing the complaint without prejudice and providing a list of defects in the complaint; by ordering service on all officers who were on duty during the incident in question; or by some other means.” Donald v.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
James T. Donald v. Cook County Sheriff's Department
95 F.3d 548 (Seventh Circuit, 1996)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Jonathon Castro v. County of Los Angeles
833 F.3d 1060 (Ninth Circuit, 2016)
Darnell v. City of New York
849 F.3d 17 (Second Circuit, 2017)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Wilson v. Ryker
451 F. App'x 588 (Seventh Circuit, 2011)

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Bluebook (online)
Beck v. Unknown Sangamon County Sheriff's Dept Employees, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beck-v-unknown-sangamon-county-sheriffs-dept-employees-ilcd-2022.