Brown v. Lakin

CourtDistrict Court, S.D. Illinois
DecidedJune 2, 2023
Docket3:22-cv-00887
StatusUnknown

This text of Brown v. Lakin (Brown v. Lakin) 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
Brown v. Lakin, (S.D. Ill. 2023).

Opinion

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

DAVID F. BROWN, #17579, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-00887-JPG ) JOHN LAKIN, ) KRISTOPHER THARP, ) STEPHEN RIDINGS, ) LIEUTENANT JOHN DOE, ) SERGEANT JOHN DOE, ) and OFFICER DECKER, ) ) Defendants. )

MEMORANDUM AND ORDER GILBERT, District Judge: This matter is before the Court for preliminary review of the Amended Complaint filed by Plaintiff David Brown pursuant to 42 U.S.C. § 1983 on October 17, 2022. (Doc. 13). Plaintiff’s claims stem from his exposure to an inmate with COVID-19 at Madison County Jail on or around January 6, 2022.1 (Id. at 1-22). He alleges that the defendants knowingly housed him with the sick detainee and caused him to contract COVID-19. (Id.). He seeks unspecified injunctive, declaratory, and monetary relief. (Id. at 5). The Amended Complaint is subject to preliminary review under 28 U.S.C. § 1915A. Section 1915A requires the Court to screen prisoner complaints to filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion that is legally frivolous, malicious, or meritless must

1 Plaintiff originally filed suit in the Circuit Court of the Third Judicial Circuit, Madison County, Illinois, Case No. 2022-LA-000391, and the case was removed to this federal judicial district on May 30, 2022. The Court found that removal was proper. The Complaint did not survive review under 28 U.S.C. § 1915A and was dismissed without prejudice and with leave to amend. (Doc. 12). be dismissed. 28 U.S.C. § 1915A(b). The Court construes the factual allegations of the pro se complaint liberally. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). Amended Complaint Plaintiff makes the following allegations in the Amended Complaint (Doc. 13, pp. 1-22):

Defendants allegedly violated Plaintiff’s rights under the Eighth and/or Fourteenth Amendments when they moved Detainee Charles Adcock into Plaintiff’s cell after learning that he tested positive for COVID-19 on January 6, 2022. (Id. at 7). “Mr. Wally”2 took Adcock for testing, after Adcock reported feeling sick for three days. (Id. at 16). Within minutes of learning that Adcock tested positive for the virus, Officer Decker placed a sign in the cell block, stating: “Quarantine: 14 Days / No One In / No One Out.” (Id. at 7, 11). Minutes later, Officer Decker moved Adcock into Cell 4 with Plaintiff and informed both detainees that the cell block was under quarantine for 14 days because Adcock tested positive for COVID-19. (Id.). Plaintiff contracted the virus several days later and still suffers from its effects. (Id. at 8, 16). Plaintiff guesses that Lieutenant John Doe or Sergeant John Doe probably gave Officer Decker the order to place Adcock in Plaintiff’s

cell. (Id. at 17). Sheriff John Lakin, Captain Kristopher Tharp, and Captain Stephen Ridings knew of the substantial risk of serious harm caused by COVID-19 and turned a blind eye to the risk posed by placing Adcock in Cell 4 with Plaintiff. (Id. at 8-9, 11, 13). According to Plaintiff, all of these defendants deliberately ignored the guidelines and information available to them about the seriousness of COVID-19 when they failed to intervene and protect Plaintiff from the serious risk of harm posed by exposure to Adcock while he was ill with COVID-19. (Id. at 19).

2 “Mr. Wally” is not listed as a defendant, and Plaintiff brings no claims against him. Discussion Based on the allegations in the Amended Complaint, the Court finds it convenient to designate the following count in this pro se action: Count 1: Fourteenth Amendment claim against Defendants for subjecting Plaintiff to unconstitutional conditions of confinement during his pretrial detention at Madison County Jail, by knowingly placing an inmate with COVID-19 into Plaintiff’s cell, or turning a blind eye to his placement there, and causing Plaintiff to contract the virus on or around January 6, 2022.

Any other claim that is mentioned in the Amended Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.3 Discussion

Because Plaintiff alleges that he was a pretrial detainee during the relevant time period, the Fourteenth Amendment objective unreasonableness standard articulated in Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018), governs his claim for unconstitutional conditions of confinement. The Fourteenth Amendment protects pretrial detainees, who have not yet been convicted of a crime, from being held in conditions that constitute punishment. Miranda, 900 F.3d at 350-51. A due process challenge to these conditions of confinement involves two inquires. First, the court must determine whether each defendant’s conduct was purposeful, knowing, or even reckless with respect to the “physical consequences in the world” of his or her conduct. Id. (quoting Kingsley v. Hendrickson, 576 U.S. 389 (2015)). Second, the court considers the objective reasonableness of each defendant’s conduct in light of the “totality of the facts and circumstances” facing the defendant. McCann v. Ogle County, 909 F.3d 881, 886 (7th Cir. 2018). The conditions created by each defendant must be objectively, sufficiently serious. Gray v. Hardy, 826 F.3d 1000, 1005 (7th Cir. 2016).

3 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (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”). The allegations articulate a claim against Officer Decker, who placed Adcock in Plaintiff’s cell after Adcock was diagnosed with COVID-19, and against Sheriff Lakin, who knowingly turned a blind eye to this placement decision and allowed Plaintiff’s exposure to the obviously harmful virus. Count 1 shall proceed against both defendants, in their individual capacities.

Count 1 shall also proceed against Sheriff Lakin, in his official capacity. Plaintiff names the sheriff, and all other defendants, in connection with certain Jail policies that allegedly caused the unconstitutional conditions of his confinement—including the policy of allowing COVID- positive and COVID-negative inmates to share the same housing or the absence of a policy requiring their separation. See Calhoun v. Ramsey, 408 F.3d 375, 380 (7th Cir. 2005) (failure to have a policy may, in some circumstances, constitute an unconstitutional policy). In Illinois, sheriffs possess final policy-making authority. See Miranda, 900 F.3d at 344 (citations omitted). Sheriff Lakin is therefore the proper party for a claim targeting policies and customs that deprived Plaintiff of his federal rights pursuant to Monell v.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Marcos Gray v. Marcus Hardy
826 F.3d 1000 (Seventh Circuit, 2016)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Valerie McCann v. Ogle County, Illinois
909 F.3d 881 (Seventh Circuit, 2018)

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Bluebook (online)
Brown v. Lakin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-lakin-ilsd-2023.