Christopher Mansoori v. James Morrison

CourtDistrict Court, N.D. Illinois
DecidedDecember 3, 2025
Docket1:21-cv-06173
StatusUnknown

This text of Christopher Mansoori v. James Morrison (Christopher Mansoori v. James Morrison) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christopher Mansoori v. James Morrison, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Christopher Mansoori,

Plaintiff, No. 21 CV 6173 v. Judge Lindsay C. Jenkins James Morrison,

Defendant.

MEMORANDUM OPINION AND ORDER Christopher Mansoori filed this lawsuit under 42 U.S.C. § 1983 alleging he endured unconstitutional conditions of confinement at Cook County Jail based on exceptionally cold temperatures inside his cell between 2019 and 2021. Defendant James Morrison has moved for summary judgment, arguing that Mansoori cannot establish that Morrison was personally involved in any constitutional deprivation, and that he cannot show that the temperature conditions were objectively unreasonable in violation of the Due Process Clause of the Fourteenth Amendment. Alternatively, Morrison argues that he is entitled to qualified immunity. Because Mansoori has presented no evidence that would allow a reasonable jury to find that Morrison was personally involved in the deprivation, and alternatively because Morrison is entitled to qualified immunity, the motion is granted. I. Northern District of Illinois Local Rule 56.1 “On summary judgment, the Court limits its analysis of the facts to the evidence that is presented in the parties’ Local Rule 56.1 statements.” Kirsch v. Brightstar Corp., 78 F. Supp. 3d 676, 697 (N.D. Ill. 2015). The statements serve a valuable purpose: they help the Court in “organizing the evidence and identifying disputed facts.” Fed. Trade Comm’n v. Bay Area Bus. Council, Inc., 423 F.3d 627, 633 (7th Cir. 2005). “To dispute an asserted fact, a party must cite specific evidentiary material that controverts the fact and must concisely explain how the cited material controverts the asserted fact. Asserted facts may be deemed admitted if not controverted with specific citations to evidentiary material.” L.R. 56.1(e)(3). Any party, including a pro se litigant, who fails to comply with Local Rule 56.1 does so at their own peril. Wilson v. Kautex, Inc., 371 F. App’x 663, 664 (7th Cir. 2010) (“[S]trictly enforcing Local Rule 56.1 was well within the district court’s discretion, even though [employee] is a pro se litigant” (cleaned up)); Collins v. Illinois, 554 F.3d 693, 697 (7th Cir. 2009) (“even pro se litigants must follow procedural rules”); Parker v. Fern, 2024 WL 1116092, at *2 (N.D. Ill. Mar. 14, 2024) (“It is well–settled that a plaintiff’s pro se status does not excuse him from complying with federal and local procedural rules.”) Here, Morrison filed a Rule 56.1 statement, and as required by Rule 56.2, Mansoori was served with a “Notice to Unrepresented Litigant Opposing Summary Judgment.” [Dkt. 131.]1 This latter filing explains what a motion for summary judgment is and what steps Mansoori needed to take to respond to the motion. As the nonmoving party, Mansoori had to file a response to each statement of fact, which he did. [Dkt. 144.] “Each response must admit the asserted fact, dispute the asserted fact, or admit in part and dispute in part the asserted fact.” L.R. 56.1(e)(2). The Local Rules also explain that a party disputing a certain fact (even if only in part) must “cite specific evidentiary material that controverts the fact and must concisely explain how the cited material controverts the asserted fact.” L.R. 56.1(e)(3). The court may deem a fact admitted if a party does not dispute the fact with “specific citations to evidentiary material.” Id. At times, Mansoori improperly disputes facts by citing material that doesn’t actually dispute the asserted fact, or he disputes a fact without citing to any evidence at all. [Dkt. 144, ¶¶ 13-16, 17, 23-25, 28, 45, 48-49, 54, 60.] For example, he disputes several facts by stating only that he disputes whether the relevant employees “did their job in this case,” or that it was the duty of a particular employee to “ensure constitutional living conditions.” These facts are not properly disputed and are therefore deemed admitted. Other times, Mansoori cites to a declaration he filed in opposition to summary judgment. In response to that, Morrison invokes the sham affidavit rule, arguing that Mansoori’s declaration does not create a genuine dispute of fact. [Dkt. 155 at 4.] The sham affidavit rule is an exception to the general principle that when there is evidence on both sides of a dispute, including self-serving affidavits, summary judgment is inappropriate. See, e.g., Foster v. PNC Bank, Nat’l Ass’n, 52 F.4th 315, 320 (7th Cir. 2022). As the Seventh Circuit has explained, [T]he sham-affidavit rule prohibits a party from submitting an affidavit that contradicts the party’s prior deposition or other sworn testimony. … The organizing principle of our sham-affidavit practice is simply stated: a genuine issue of material fact cannot be conjured out of nothing. We adopted the sham- affidavit rule to weed out unfounded claims, specious denials, and sham defenses. James v. Hale, 959 F.3d 307, 316 (7th Cir. 2020) (cleaned up). The sham affidavit rule is narrow. It does not bar an affiant from trying to clarify or explain away seemingly

1 Citations to docket filings generally refer to the electronic pagination provided by CM/ECF, which may not be consistent with page numbers in the underlying documents. damaging testimony. See Seshadri v. Kasraian, 130 F.3d 798, 801-802 (7th Cir. 1997). Nor does it require striking an affidavit in full; only the contradictory portions are disregarded. See Dunn v. Menard, Inc., 880 F.3d 899, 910–12 (7th Cir. 2018). Accordingly, the court will disregard any offending portion of Mansoori’s declaration. It also disregards those portions that are not based on personal knowledge. Fed. R. Civ. P. 56(c)(4) (An affidavit or declaration offered in opposition to summary judgment “must be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters stated.”) Finally, should a party wish to set forth facts not present in or fairly responsive to the nonmoving party’s statement, they may do so by submitting an additional statement of material facts. L.R. 56.1(b)(3). The additional statement of facts is subject to the same rules that governed the moving party’s statement of facts, meaning it must cite “specific evidentiary material, including the specific page number, that supports it.” L.R. 56.1(2). Mansoori filed an additional statement of facts, and the court considers it to the extent supported by the cited evidentiary material. [Dkt. 156.] Consequently, when Mansoori does not properly dispute them, the court deems Morrison’s facts admitted. It also considers relevant facts properly set forth in Mansoori’s statement of additional facts and recounts the material facts as favorably to Mansoori as the record and Local Rule 56.1 permit. II. Background Mansoori entered Cook County Jail in October 2019. [Dkt. 144, ¶ 4.] First, he was housed in Division 6, Tier 1N; later, he was transferred to Division 4, Tier J1. [Id., ¶¶ 7, 51.] According to Mansoori, while in Division 6, cell temperatures were as cold as 45° to 51° Fahrenheit, which caused his teeth to chatter, and prevented him from sleeping. He also suffered headaches and became ill. [Id., ¶ 9.] On a day in November 2019 when the outside temperature plummeted to single digits, Mansoori could see his breath, could not feel his toes when wearing shoes and socks, and his cell felt like a freezer.

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Christopher Mansoori v. James Morrison, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-mansoori-v-james-morrison-ilnd-2025.