Brandon Jackson v. Richard Arnold, David Mitchell, and Rob Jeffreys

CourtDistrict Court, S.D. Illinois
DecidedMarch 30, 2026
Docket3:23-cv-02856
StatusUnknown

This text of Brandon Jackson v. Richard Arnold, David Mitchell, and Rob Jeffreys (Brandon Jackson v. Richard Arnold, David Mitchell, and Rob Jeffreys) 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
Brandon Jackson v. Richard Arnold, David Mitchell, and Rob Jeffreys, (S.D. Ill. 2026).

Opinion

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

BRANDON JACKSON ) ) Plaintiff, ) ) vs. ) Case No. 23-cv-2856-SMY ) RICHARD ARNOLD, DAVID ) MITCHELL, and ROB JEFFREYS ) ) Defendant. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Brandon Jackson, currently incarcerated at the Cook County jail, filed this lawsuit under 42 U.S.C. § 1983 against Chaplain Richard Arnold, Warden David Mitchell, and Assistant Wardan Rob Jeffreys, alleging constitutional violations of his religious freedom. Now pending before the Court is Defendants’ motion for summary judgment (Doc. 37). Plaintiff did not file a response.1 For the following reasons, the motion is GRANTED in part. Factual Background The following facts, derived from Plaintiff’s deposition and Chaplain Arnold’s affidavit, are undisputed unless otherwise indicated: Plaintiff Brandon Jackson, a practicing Muslim, was incarcerated at Pinckneyville Correctional Center during the events at issue (Doc. 37-1, pp. 9–10). From 2019 through 2021, he participated in Ramadan, Jumu’ah, and Taleem services without incident (Id. at 9, ¶¶ 7–10). Under 20 Ill. Admin. Code § 425.70, inmates must submit written

1 When a party fails to respond, the Court may accept the movant’s statement of facts as true. FED. R. CIV. P. 56(e)(2). Accordingly, the Court accepts Defendant’s statement of facts as true in considering the instant motion for summary judgment. requests for religious-diet accommodations 45 days before the observance begins (Doc. 37-2, pp. 1–2, ¶ 3). In prior years, Pinckneyville posted Ramadan sign-up information on housing-unit bulletin boards, and Jackson routinely complied through that process (Doc. 37-1, pp. 14–15). In 2022, Ramadan lasted from April 1 to April 30 (Doc. 37-2, p. 2, ¶ 7). During Ramadan, practicing Muslims fast from sunrise to sunset and break the fast after sunset (Doc. 37-1, p. 11).

After the observance began, Jackson learned from Chaplain Arnold that he was not on the participation list because he had missed the sign-up deadline (Doc. 37-2, pp. 2, ¶¶ 8–9). Unlike in previous years, the 2022 notice was not posted on bulletin boards but appeared only on the institutional television channel (Doc. 37-1, p. 15). Jackson was not informed the sign-up notice would be distributed through the institutional television system, nor did he receive notice from any other source (Id., p. 16). As a result, Jackson was excluded from evening meals and congregational prayers. Jackson filed grievance, observed Ramadan on his own, and broke his fast with food purchased from commissary (Doc. 37, pp. 3–4, ¶¶ 12–13, 16). In 2023, Pinckneyville

automatically enrolled him for Ramadan (Doc. 37-1, p. 29, ¶¶ 8–12). Jackson seeks policy change, not financial compensation (Id. at pp. 38–40, 44). Discussion Summary judgment is proper only if the moving party can demonstrate that there is no genuine issue as to any material fact. Fed. R. Civ. P. 56(a); Alabama v. North Carolina, 560 U.S. 330, 344 (2010). The moving party is entitled to summary judgment if the non-moving party “has failed to make a sufficient showing on an essential element of [his] case with respect to which [he] has the burden of proof.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). If the evidence is merely colorable or not sufficiently probative, summary judgment may be granted. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249–50 (1986). Any doubt as to the existence of a genuine issue of material fact must be resolved against the moving party. Lawrence v. Kenosha Cnty., 391 F.3d 837, 841 (7th Cir. 2004). First Amendment To establish a free exercise claim, Jackson “had to submit evidence from which a jury

could reasonably find that the defendants personally and unjustifiably placed a substantial burden on his religious practices.” Thompson v. Holm, 809 F.3d 376, 379 (7th Cir. 2016) (citing Hernandez v. C.I.R., 490 U.S. 680, 699 (1989)). A substantial burden is one that “put[s] substantial pressure on an adherent to modify his behavior and to violate his beliefs.” Thomas v. Review Bd., 450 U.S. 707, 718 (1981). In the prison context, such a burden is justified if it is “reasonably related to a legitimate penological interest.” Thompson, 809 F.3d at 380 (citing Turner v. Safley, 482 U.S. 78, 89–91 (1987)). Wardens David Mitchell and Rob Jeffreys Despite never meeting or speaking with Defendants David Mitchell and Rob Jeffreys,

Jackson named them based on his belief that as wardens, they were notified of the Ramadan sign- up issue through his grievance process and were therefore “responsible in that capacity” (Doc. 37- 1, pp. 22–23). Citing Exhibit 3, bates 1, Defendants contend that Jackson’s grievance “did not come before the warden[s] until after Ramadan [] to put them on notice”, and that respondeat superior does not apply to Jackson’s claims (Doc. 37, p. 9). Exhibit 1, Jackson’s deposition transcript, and Exhibit 2, Chaplain Arnold’s declaration are attached to Defendants’ motion; Exhibit 3 was not attached and will not be considered. That said, an attachment to Jackson’s Complaint, specifically Defendants grievance response (Doc. 2, pp. 25–27), establishes these defendants did not become aware of the incident until after the completion of the 2022 Ramadan. As such, they are entitled to summary judgment. Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009) (“Government officials may not be held liable for the unconstitutional conduct of their subordinates under a theory of respondeat superior.”); Minix v. Canarecci, 597 F.3d 824, 833 (7th Cir. 2010) (“individual liability under § 1983 requires ‘personal involvement in the alleged constitutional deprivation’”).

Chaplain Richard Arnold Chaplain Arnold argues he did not violate Jackson’s First Amendment Rights by requiring him to sign up for Ramadan in accordance with the Illinois Administrative Code, which serves legitimate penological interests. The issue, however, is whether providing the sign-up notice solely through the institutional television channel was constitutionally sufficient. Here, the record shows that Ramadan diet sign-up information had been posted on housing- unit bulletin boards in years prior to 2022, and Jackson successfully enrolled through that method. However, in 2022, the sign-up notice was distributed only through the institutional television channel, which Jackson did not see and asserts he was unaware of (Doc. 37-1, pp. 13–15). This

creates a material issue of fact as to whether notice distributed only via the institutional television channel, which displays information momentarily rather than continuously like a posted bulletin, comported with the First Amendment’s free-exercise protection in the prison context. See Conyers v. Abitz,

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
Hernandez v. Commissioner
490 U.S. 680 (Supreme Court, 1989)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Alabama v. North Carolina
560 U.S. 330 (Supreme Court, 2010)
Colleen P. Kramer v. Banc of America Securities, LLC
355 F.3d 961 (Seventh Circuit, 2004)
Darrick Lawrence v. Kenosha County and Louis Vena
391 F.3d 837 (Seventh Circuit, 2004)
Blake Conyers v. Tom Abitz
416 F.3d 580 (Seventh Circuit, 2005)
Minix v. Canarecci
597 F.3d 824 (Seventh Circuit, 2010)
Thompson v. Holm
809 F.3d 376 (Seventh Circuit, 2016)
Howell v. Smith
853 F.3d 892 (Seventh Circuit, 2017)
Easterling v. Pollard
528 F. App'x 653 (Seventh Circuit, 2013)

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