Corey Anderson v. Jack Harlan

CourtDistrict Court, C.D. Illinois
DecidedDecember 5, 2025
Docket4:25-cv-04071
StatusUnknown

This text of Corey Anderson v. Jack Harlan (Corey Anderson v. Jack Harlan) 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
Corey Anderson v. Jack Harlan, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

COREY ANDERSON, ) Plaintiff, ) ) v. ) Case No. 4:25-cv-4071-SEM-DJQ ) JACK HARLAN, ) Defendant. )

MERIT REVIEW ORDER

SUE E. MYERSCOUGH, United States District Judge:

Plaintiff pro se Corey Anderson filed a Complaint under 42 U.S.C. § 1983. On October 2, 2025, the Court dismissed Plaintiff’s Complaint without prejudice for failure to state a claim and gave Plaintiff leave to amend. (Doc. 7). The Court warned Plaintiff this case would be dismissed with prejudice if his Amended Complaint still failed to state a claim. Id. at p. 6. On November 19, 2025, Plaintiff filed an Amended Complaint. (Doc. 10). This matter is now before the Court for screening. For the following reasons, Plaintiff’s Amended Complaint fails to state a claim, and this case is dismissed with prejudice. I. Screening Standard The Court must “screen” Plaintiff’s Amended Complaint

and dismiss any legally insufficient claim or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon

which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. In reviewing Plaintiff’s Amended Complaint, the 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).

II. Facts Alleged At all times relevant to his Amended Complaint, Plaintiff was detained at the Knox County Jail (“Jail”). Plaintiff files suit against the Jail, Knox County Sheriff Jack Harlan, and

Correctional Officers Lindsey May, Barbara Schulz, Brad Abernathy, and Turn Key. First, Plaintiff alleges the Jail implemented a policy to eliminate in-person visits and replace them with video visits.

Plaintiff states the Jail charges a $6.48 fee and a $9.00 processing fee for a 15-minute video visit. Plaintiff alleges the fees are too costly. As a result, he is unable to visit with his

fiancé and family members. Plaintiff asserts the Jail’s policy is not rationally related to legitimate penological interests. Second, Plaintiff alleges the Jail implemented a policy or

custom to confine Plaintiff and other inmates to their cells for 31 hours. Plaintiff alleges he was confined to his cell for 31 hours on February 28, 2025, March 1, 2025, and March 2,

2025, and was denied access to recreation, programming, medical care, and the law library. Plaintiff filed a grievance on March 1, 2025, and received a response from Defendant

Abernathy, who stated that “the facility has been on this same tier system before and IDOC is aware and has no issues with how we run this facility.” (Doc. 10 at p. 3). Third, Plaintiff alleges he was denied access to the courts

because the Jail’s law library is inadequate. Plaintiff alleges the library staff cannot print cases or locate necessary legal materials. On April 19, 2025, Plaintiff asked to print legal documents, but Defendant Abernathy allegedly told him that

“printing is not available for inmates.” Id. The same day, Plaintiff filed a grievance requesting the ability to print legal paperwork. Plaintiff received a final response to his grievance

from Defendant Abernathy, who advised Plaintiff to “ask the courts for assistance.” Id. III. Analysis

Upon review of the allegations in the Amended Complaint, Plaintiff has failed to state a claim for relief. Plaintiff attempts to allege three claims in his Amended

Complaint: (1) a claim regarding the Jail’s video-only visitation policy; (2) a conditions of confinement claim regarding 31-hour lockdowns; and (3) an access to courts claim based on the

Jail’s allegedly inadequate law library and inability to print legal documents. The Jail is not a “person” amenable to suit under § 1983. Dye v. Wargo, 253 F.3d 296, 299 (7th Cir. 2001); see also

Nava v. Sangamon Cnty. Jail, No. 14-3090, 2014 WL 1320259, at *2 (C.D. Ill. Apr. 2, 2014) (“‘Sangamon County Jail’ is not a ‘person’ that may be sued under § 1983”); Wright v. Porter Cnty., No. 12-493, 2013 WL 1176199, at *2 (N.D. Ind. Mar. 19,

2013) (“the jail…is a building, not a ‘person’ or even a policy- making body that can be sued for constitutional violations”). The Knox County Jail is dismissed.

Plaintiff named Defendants Sheriff Harlan and Correctional Officers Lindsey May, Barbara Schulz, and Turn Key, but he did not include any specific allegations against

them in the body of his Amended Complaint to explain how they were personally involved in violating his constitutional rights. Individual liability under § 1983 can only be based

upon a finding that the defendant caused the deprivation alleged. 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.”). Defendants Harlan, May, Schulz, and Key are dismissed.

That leaves Defendant Brad Abernathy. Plaintiff alleges Defendant Abernathy responded to his grievances regarding the 31-hour lockdowns and his request to print legal documents. Plaintiff’s threadbare allegations are insufficient to

state a claim. Additionally, “the alleged mishandling of [a prisoner’s] grievance by persons who otherwise did not cause or participate in the underlying conduct states no claim.”

Owens v. Hinsley, 635 F.3d 950, 953 (7th Cir. 2011). Plaintiff also alleges Defendant Abernathy did not grant his request to print legal documents on April 19, 2025. To

establish an access to courts claim, Plaintiff must allege facts plausibly suggesting that the “[jail] officials failed to assist in the preparation and filing of meaningful legal papers . . . [and]

some quantum of detriment caused by the challenged conduct of [the] officials.” Lehn v. Holmes, 364 F.3d 862, 868 (7th Cir. 2004) (quoting Brooks v. Buscher, 62 F.3d 176, 179 (7th Cir.

1995)). In a conclusory fashion, Plaintiff alleges he is representing himself in “ongoing legal matters, including the criminal case underlying the current detention,” but he does not allege “that some action by the [jail] has frustrated or is

impeding an attempt to bring a nonfrivolous legal claim.” In re Maxy, 674 F.3d 658, 661 (7th Cir. 2012); Doc. 10 at p. 3. Plaintiff’s allegations are insufficient to proceed on an access to courts claim against Defendant Abernathy. Defendant

Abernathy is dismissed.

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Related

Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
In Re Maxy
674 F.3d 658 (Seventh Circuit, 2012)
Brooks v. Buscher
62 F.3d 176 (Seventh Circuit, 1995)
Curtis J. Celske v. Thomas Edwards
164 F.3d 396 (Seventh Circuit, 1999)
Donald A. Lehn v. Michael L. Holmes
364 F.3d 862 (Seventh Circuit, 2004)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)

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