Christopher L. Wilson v. Tom Dart, et al.

• Court: District Court, C.D. Illinois
• Decided: March 17, 2026
• Docket: 4:26-cv-04022
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

CHRISTOPHER L. WILSON, Plaintiff,

v. Case No. 4:26-cv-04022-JEH

TOM DART, et al., Defendants.

Merit Review Order On December 16, 2025, Plaintiff Christopher Wilson, proceeding pro se and currently in custody at the Grundy County Jail, filed a Complaint under 42 U.S.C. § 1983 alleging violations of his constitutional rights. (Doc. 1). The case was transferred to this Court from the United States District Court for the Northen District of Illinois on January 26, 2026. (Docs. 7, 8). The case is before this Court for a merit review pursuant to 28 U.S.C. § 1915A. I 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 F. App’x 588, 589 (7th Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). II Plaintiff files suit against Tom Dart, Cook County, Cook County Medical Staff, Jack Harlon, Knox County, and Knox County Medical Staff. Plaintiff alleges he was transferred from the Cook County Jail to the Knox County Jail in September 2024. Plaintiff claims that while in custody at the Knox County Jail, he was not provided with adequate medical attention for his eye issues. He also complains that Knox County Jail officials failed to protect him from an inmate attack in February 2025. Plaintiff claims Cook County staff members failed to protect him by transferring him to the Knox County Jail, where he was attacked by another inmate and did not have his medical issues addressed. There is no indication that the Cook County Defendants knew Plaintiff would be harmed by transferring him to the Knox County Jail. Defendants Tom Dart, Cook County, and Cook County Medical Staff are DISMISSED WITHOUT PREJUDICE for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6) and § 1915A. Regarding Defendants Sheriff Jack Harlon and Knox County Medical Staff, Plaintiff did not include any specific allegations to demonstrate how Defendants were personally involved in any constitutional deprivation. Vance v. Peters, 97 F.3d 987, 991 (7th Cir. 1996) (“Section 1983 creates a cause of action based on personal liability and predicated upon fault; thus, liability does not attach unless the individual defendant caused or participated in a constitutional deprivation.”). There is no respondeat superior under § 1983. In other words, Defendant Sheriff Harlon cannot be liable based only on his supervisory position. Doe v. Purdue Univ., 928 F.3d 652, 664 (7th Cir. 2019). Officials are accountable for their own acts; they are not vicariously liable for the conduct of subordinates. See Ashcroft v. Iqbal, 556 U.S. 662, 667 (2009); Vance v. Rumsfeld, 701 F.3d 193, 203-05 (7th Cir. 2012) (en banc). If Jail officials are named, they must be named in their individual capacities, and Plaintiff must allege that the official personally participated in the deprivation or was deliberately reckless as to the misconduct of subordinates or was aware and condoned, acquiesced, or turned a blind eye to it. Sanville v. McCaughtry, 266 F.3d 724, 740 (7th Cir. 2001). Plaintiff’s Complaint is DISMISSED WITHOUT PREJUDICE for failure to state a claim for relief under Federal Rule of Civil Procedure 12(b)(6) and § 1915A. The Court will allow Plaintiff a final opportunity to file an Amended Complaint within 30 days of this Order. If Plaintiff fails to file a timely Amended Complaint, or if the Amended Complaint fails to state a claim for relief, his case will be dismissed with prejudice. Plaintiff’s Amended Complaint will replace Plaintiff’s Complaint in its entirety. The Amended Complaint must contain all allegations against all Defendants. Piecemeal amendments are not accepted. IT IS THEREFORE ORDERED: 1) Plaintiff's Complaint is DISMISSED WITHOUT PREJUDICE for failure to state a claim for relief under Federal Rule of Civil Procedure 12(b)(6) and 28 U.S.C. § 1915A. The Court will allow Plaintiff a final opportunity to file an Amended Complaint within 30 days of this Order. If Plaintiff fails to file a timely Amended Complaint, or if the Amended Complaint fails to state a claim for relief, his case will be dismissed with prejudice. Plaintiff's Amended Complaint will replace Plaintiff's Complaint in its entirety. The Amended Complaint must contain all allegations against all Defendants. Piecemeal amendments are not accepted.

2) The Clerk is directed to send Plaintiff a blank Section 1983 complaint form.

It is so ordered.

Entered: March 17, 2026

s/Jonathan E. Hawley U.S. District Judge