Clemons v. Snyder

CourtDistrict Court, C.D. Illinois
DecidedJune 2, 2025
Docket4:25-cv-04103
StatusUnknown

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

Bluebook
Clemons v. Snyder, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

JOSHUA CLEMONS, ) Plaintiff, ) ) v. ) Case No. 25-4103 ) GREGG SNYDER et al., ) Defendants. )

ORDER COLLEEN R. LAWLESS, United States District Judge: Plaintiff Joshua Clemons is civilly committed at the Illinois Department of Human Services Treatment and Detention Facility (“TDF”) under the Illinois Sexually Violent Persons Commitment Act, 725 ILCS 207/1 et seq. Plaintiff has filed a Complaint (Doc. 1) under 42 U.S.C. § 1983 that is before the Court for screening. Plaintiff has also filed a Petition to Proceed in forma pauperis (“IFP”) (Doc. 3), a Motion for Counsel (Doc. 5), a Motion to Waive Filing Fee (Doc. 4), and a Motion to Reconsider (Doc. 7). I. Background In January 2025, Plaintiff and three other TDF residents, Chad Wahl, Gregory Morris, and Charles Parker, collectively filed a Complaint in case No. 24-4014, which was severed based on a finding that joinder of the Plaintiffs’ claims was inappropriate. (Id. at Dkt. 22 at 2.)

Page 1 of 8 II. Complaint A. Screening Standard The “privilege to proceed without posting security for costs and fees is reserved to the many truly impoverished litigants who, within the District Court’s sound discretion, would remain without legal remedy if such privilege were not afforded to

them.” Brewster v. North Am. Van Lines, Inc., 461 F.2d 649, 651 (7th Cir. 1972). Additionally, a court must dismiss cases proceeding IFP “at any time” if the action is frivolous, malicious, or fails to state a claim, even if part of the filing fee has been paid. 28 U.S.C. § 1915(d)(2). In reviewing the pleading, the district court accepts the factual allegations as

accurate, liberally construing them in the plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (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 omitted). B. Facts Alleged Plaintiff’s pleading identifies Sarah D. Culbertson Memorial Hospital and its Chief

Executive Officer, Gregg Snyder, as Defendants. Plaintiff has resided at TDF since 2001. Medical providers at Sarah D. Culbertson Memorial Hospital (“Hospital”) treated Plaintiff for various medical issues. During these visits, Plaintiff was required to provide his identifying information and medical history. (Pl. Compl., Doc. 1 at 2.) On November 21, 2023, Plaintiff received a notification from Page 2 of 8 Defendant Snyder that a data breach of the Hospital’s computer system potentially exposed his identifying information to third parties. Plaintiff wrote letters to Defendant Snyder and the law firm representing the Hospital, informing them that his detention at TDF foreclosed access to the internet, control of his medical records, and access to the one-year Equifax identity monitoring

service subscription. Although Plaintiff acknowledges receiving a letter from an attorney representing the Hospital, he claims the “general” response was inadequate to address the data breach. The plaintiff asserts that Defendants violated his constitutional rights to privacy, due process, and regulations under federal and state law. C. Analysis

The Seventh Circuit has recognized a Fourteenth Amendment right “to the privacy of medical, sexual, financial, and perhaps other categories of highly personal information.” Doe v. Gray, 75 F.4th 710, 717 (7th Cir. 2023). Assuming Plaintiff’s confidential information was disclosed in the data breach, Plaintiff’s allegations do not permit a plausible inference that Defendant Snyder was personally involved in disclosing

Plaintiff’s information or that the data breach resulted from a hospital policy Defendant Snyder knew would violate Plaintiff’s constitutional rights. 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.”); Monell v. Dep’t of Social Srvcs. of City of New York, 436 U.S. 658 (1978). Page 3 of 8 Plaintiff’s allegations that Defendant Snyder and other hospital officials were negligent are insufficient to state a constitutional claim. “[N]egligence, even gross negligence, does not violate the Constitution.” McGowan v. Hulick, 612 F.3d 636, 640 (7th Cir. 2010); see also Aguilar v. Gaston-Camara, 861 F.3d 626, 633 (7th Cir. 2017) (“[T]he Eighth Amendment is violated by acts or omissions that exhibit deliberate indifference; mere

negligence is insufficient. . . . Similarly, negligent conduct by a state official does not implicate the Due Process Clause.”); Pierson v. Hartley, 391 F.3d 898, 902 (7th Cir. 2004) (“Negligence on the part of an official does not violate the Constitution, and it is not enough that he or she should have known of a risk.”). Furthermore, the fact that Plaintiff was civilly detained at the time he received

services from a private hospital does not, on its own, automatically permit an inference that hospital officials were state actors for purposes of 42 U.S.C. § 1983. See DiDonato v. Panatera, 24 F.4th 1156, 1159 (7th Cir. 2022) (determination of whether an individual was acting under the color of state law depends on whether the individual exercised authority he “possessed by virtue of state law” and made possible only because of such authority).

Plaintiff does not cite a federal statute or rule that provides a private cause of action for the unauthorized disclosure of medical information, and courts deciding the issue have held that the Health Insurance Portability and Accountability Act does not provide one. Carpenter v. Phillips, 419 F. App’x 658, 659 (7th Cir. 2011). Consequently, Plaintiff’s Complaint is dismissed for failure to state a claim.

However, if Plaintiff believes he can revise his pleading to state a cause of action, he may Page 4 of 8 file a motion for leave to file an amended complaint. If Plaintiff decides to file an amended complaint, his amended pleading must be attached to his motion for leave. The Court does not accept piecemeal amendments. Plaintiff’s amended pleading must stand independently without reference to his initial filing and contain all claims against all defendants. Plaintiff’s amendment must specify the constitutional violation,

when it occurred, and the Defendant or Defendants personally involved. See Gentry v. Duckworth, 65 F.3d 555, 561 (7th Cir.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
McGowan v. Hulick
612 F.3d 636 (Seventh Circuit, 2010)
Robert L. Brewster v. North American Van Lines, Inc.
461 F.2d 649 (Seventh Circuit, 1972)
Robert Lumbert v. Illinois Department of Corrections
827 F.2d 257 (Seventh Circuit, 1987)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Daniel Aguilar v. Janella Gaston-Camara
861 F.3d 626 (Seventh Circuit, 2017)
Carpenter v. Phillips
419 F. App'x 658 (Seventh Circuit, 2011)

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Clemons v. Snyder, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clemons-v-snyder-ilcd-2025.