Bobby Tatum v. William Christopher, Billy Austin, and Kelly Beal

CourtDistrict Court, S.D. Illinois
DecidedDecember 12, 2025
Docket3:25-cv-01474
StatusUnknown

This text of Bobby Tatum v. William Christopher, Billy Austin, and Kelly Beal (Bobby Tatum v. William Christopher, Billy Austin, and Kelly Beal) 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
Bobby Tatum v. William Christopher, Billy Austin, and Kelly Beal, (S.D. Ill. 2025).

Opinion

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

BOBBY TATUM,

Plaintiff,

v. Case No. 25-cv-1474-NJR

WILLIAM CHRISTOPHER, BILLY AUSTIN, and KELLY BEAL,

Defendants.

MEMORANDUM AND ORDER ROSENSTENGEL, Chief Judge: Plaintiff Bobby Tatum, an inmate of the Illinois Department of Corrections who is currently incarcerated at Pinckneyville Correctional Center, brings this action pursuant to 42 U.S.C. § 1983 for deprivations of his constitutional rights while at Shawnee Correctional Center. On July 24, 2025, Tatum filed his Complaint alleging retaliation, excessive force, sexual assault, and conditions of confinement claims against officials at Shawnee (Doc. 1). On August 1, 2025, Tatum filed an Amended Complaint narrowing his claims to just three individuals (Doc. 11). The claims appeared to be duplicative of claims in another case, Tatum v. Galloway, Case No. 25-cv-1352-DWD, and the Court directed Tatum to show cause as to why this later filed case should not be dismissed (Doc. 23). Tatum responded that he had not properly exhausted his claims prior to filing the earlier case and sought to pursue the claims in this case now that they were exhausted (Doc. 24). He subsequently dismissed the previously filed case. See Tatum v. Galloway, Case No. 25-cv-1352-DWD, Doc. 19. He also filed a motion to dismiss in this case but noted that he intended to pursue his claims in this case and sought to withdraw or dismiss the earlier filed case (Doc. 27).

Because Tatum’s motion merely informs the Court of his desire to proceed with this case, the motion (Doc. 27) and a motion for status of the motion (Doc. 28) are DENIED as moot. This case is now before the Court for preliminary review of the Amended Complaint pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon

which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). The Amended Complaint Tatum focuses his claims on just three defendants: William Christopher, Billy Austin, and Kelly Beal (Doc. 11, p. 2). He alleges that on August 6, 2023, after a use of

force incident involving Correctional Officer (“C/O”) Craig and Sergeant Plot, Lieutenant Austin and William Christopher walked Tatum through the prison while severely injured and with his pants and underwear on the ground at his ankles (Id. at p. 5). They exposed Tatum’s private parts to other inmates and staff, refusing to pull Tatum’s pants up despite his pleas for them to do so (Id.). They later dropped him to the

ground on his head, causing him to lose consciousness (Id.). He awoke to Lieutenant Beal sexually assaulting him with a stick (Id.). All three officers then sexually assaulted him (Id. at p. 6). The officers yelled at the other inmates, informing them that this is what happens to inmates who file grievances and lawsuits against staff and Warden Galloway (Id.). After the assault, the officers allegedly took Tatum to segregation where Sergeant Sherrod used excessive force and Beal denied Tatum’s requests for medical care. Tatum

was then placed him in a cell with unsanitary conditions (Id.). Tatum alleges a nurse tried to provide him medical care, but Beal told her to leave (Id.). Tatum was later informed that Warden Galloway ordered the three officers to attack and kill Tatum for filing lawsuits and grievances (Id.). Preliminary Dismissals

Tatum identifies a number of individuals in his statement of claim who he fails to identify as defendants in the case caption. He alleges that C/O Craig and Sergeant Plot used excessive force against him just prior to the events in this lawsuit, Sergeant Sherrod used excessive force upon Tatum’s arrival at the segregation holding cell, and Warden Galloway ordered the sexual assault allegedly perpetrated by the named defendants in this case. In order to be a party in the case, a plaintiff must identify them in the case

caption. See FED. R. CIV. P. 10(a); Myles v. United States, 416 F.3d 551, 551–52 (7th Cir. 2005). Because he fails to identify these individuals as defendants, any potential claim against them is DISMISSED without prejudice. Tatum also states in conclusory fashion that the defendants wrote a false disciplinary ticket against him. He later alleges that all three defendants violated his

Fourteenth Amendment rights when they wrote a false disciplinary ticket against him to cover up their actions (Doc. 11, pp. 6-7). The receipt of a false disciplinary ticket does not, on its own, amount to a due process violation. Hadley v. Peters, 841 F. Supp. 850, 856 (C.D. Ill. 1994), aff'd, 70 F.3d 117 (7th Cir. 1995) (citations omitted); see also Hanrahan v. Lane, 747 F.2d 1137, 1140 (7th Cir. 1984). And Tatum fails to provide any allegations regarding the proceedings related to that ticket or its outcome. He fails to allege that his due process

rights were violated in regard to the disciplinary ticket. Thus, any potential Fourteenth Amendment claim is DISMISSED without prejudice. Discussion

Based on the allegations in the Amended Complaint, the designates the following counts: Count 1: Eighth Amendment excessive force claim against William Christopher, Kelly Beal, and Billy Austin for their use of force against Tatum on August 6, 2023.

Count 2: Eighth Amendment deliberate indifference to medical needs claim against Kelly Beal for denying Tatum access to medical care.

Count 3: First Amendment retaliation claim against William Christopher, Kelly Beal, and Billy Austin for attacking Tatum in response to Tatum filing grievances.

The parties and the Court will use these designations in all future pleadings and orders, unless otherwise directed by a judicial officer of this Court. Any other claim that is mentioned in the Amended Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard.1

1 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 to relief that is plausible on its face”). At this stage, Tatum states viable claims against the defendants. He adequately alleges that all three defendants used excessive force against him and that they did so in

response to Tatum filing grievances at the prison. He also adequately alleges that Beal denied him medical care when Beal refused Tatum’s requests for treatment and denied a nurse access to Tatum. Thus, Counts 1, 2, and 3 shall proceed. Motion for Counsel Tatum also filed two motions requesting the assignment of counsel (Docs. 3, 25, 26). Tatum states that he needs counsel because he will have difficulties litigating his

claims because he is no longer at the prison where his claims occurred. But given the early stage of the case, the Court finds that counsel is not necessary at this time. Defendants have yet been served nor have they filed Answers.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Michael Hanrahan v. Michael P. Lane
747 F.2d 1137 (Seventh Circuit, 1984)
Samuel H. Myles v. United States
416 F.3d 551 (Seventh Circuit, 2005)
Hadley v. Peters
841 F. Supp. 850 (C.D. Illinois, 1994)

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