Crawford v. Clark

CourtDistrict Court, S.D. Illinois
DecidedMay 3, 2023
Docket3:22-cv-01173
StatusUnknown

This text of Crawford v. Clark (Crawford v. Clark) 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
Crawford v. Clark, (S.D. Ill. 2023).

Opinion

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

JARED R. CRAWFORD, ) ) Plaintiff, ) vs. ) Case No. 3:22-cv-01173-SMY ) JAYSON CLARK, KENNY SHIRES, ) HARRISBURG POLICE DEPT., ) GUS ZERTUCHE, DOUG DUVALL, ) SALATHIEL JOHNSON, ) DAVID MITCHELL, TIFFANIE CLARK, ) DONALD KEITH BROWN, ) ROB JEFFREYS, and ) UNKNOWN OTHERS (Illinois River CC ) and Pinckneyville CC Employees), ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Jared R. Crawford filed this lawsuit while he was incarcerated in the Franklin County Jail, seeking relief pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. Plaintiff was recently moved to the Washington County Jail (Doc. 17).1 This case is now before the Court for preliminary review of the Complaint under 28 U.S.C. § 1915A. Any portion of the Complaint that is legally frivolous, malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 1): He was charged with aggravated battery in 2016 in Harrisburg, Illinois, which resulted in his conviction and a 5-year sentence. Defendants Shires, Clark, Zertuche, and Johnson engaged in misconduct in connection

1 Plaintiff states he is in county jail awaiting disposition of a pending federal criminal case (Doc. 1, p. 6). with that case. Plaintiff was then “unlawfully imprisoned” from 2018 until his conviction was reversed on appeal in June 2021 and the charges were dismissed in March 2022. While Plaintiff was incarcerated at Pinckneyville Correctional Center, he was subjected to cruel punishment, unfair treatment, and harassment by Defendant Duval and others. He was

moved to Illinois River Correctional Center, where he was injured and was on suicide watch. Plaintiff seeks monetary damages. Discussion To survive preliminary review under § 1915A, a Complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief,” FED. R. CIV. P. 8(a)(2), which includes “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 547 (2007). The Complaint must also associate specific defendants with specific claims, so that defendants are put on notice of the claims brought against them and they can properly answer the Complaint. Id. at 555. And because Plaintiff brings his claims under § 1983, he must allege that each defendant was personally involved in the deprivation

of a constitutional right. Matz v. Klotka, 769 F.3d 517, 528 (7th Cir. 2014). Plaintiff ‘s allegations are vague and sparse, and therefore violate Rule 8 and Twombly.2 He fails to include any facts supporting his claims of unspecified cruel and unusual punishment, unfair treatment, and harassment during his incarceration at Pinckneyville and Illinois River Correctional Centers. The Complaint also runs afoul of the rules of joinder. FED. R. CIV. P. 18-21. Specifically, Federal Rule of Civil Procedure 20 prohibits a plaintiff from asserting unrelated claims against different defendants or sets of defendants in the same lawsuit. In other words, multiple defendants

2 The Complaint also violates Federal Rule of Civil Procedure 10(b) as the allegations are not set forth in separately numbered paragraphs. may not be joined in a single action unless the plaintiff asserts at least one claim to relief against each defendant that arises out of the same transaction or occurrence or series of transactions or occurrences and presents a question of law or fact common to all. FED. R. CIV. P. 18, 20(a)(2); George v. Smith, 507 F.3d 605, 607 (7th Cir. 2007).

Plaintiff's claims relating to his 2016 prosecution involve one set of defendants (county and municipal officials as well as private parties). The incidents at Pinckneyville that gave rise to Plaintiff’s claims there are distinct in time and place from the incidents at Illinois River, and different Defendants are involved at each prison. Thus, the Complaint presents at least three sets of claims against different Defendants, based on different legal theories, and these sets of claims arise from separate transactions or occurrences. Pursuant to Dorsey v. Varga, 55 F.4th 1094, 1107-08 (7th Cir. 2022), Plaintiff’s Complaint will be stricken based on the improper joinder issues described above. He may pursue only related claims against a single group of defendants in this case and must file separate lawsuits to pursue his other claims. Because Plaintiff is in the best position to decide which claims he intends to

pursue in this lawsuit, he will be given an opportunity to amend the Complaint before the Court conducts the required merits screening of his claims under § 1915A. Disposition The Complaint (Doc. 1) is STRICKEN for improper joinder of claims and/or defendants. Plaintiff is GRANTED leave to file a First Amended Complaint on or before June 5, 2023 that focuses on one claim or set of related claims against one or more defendants that arises from a single transaction or occurrence or series of transactions or occurrences. An amended complaint supersedes and replaces the original complaint, rendering it void. See Flannery v. Recording Indus. Ass’n of Am., 354 F.3d 632, 638 n. 1 (7th Cir. 2004). Therefore, the Court will not accept piecemeal amendments to the original Complaint. The First Amended Complaint must stand on its own, without reference to any previous pleading, and Plaintiff must re-file any exhibits he wishes the Court to consider along with the First Amended Complaint. The First Amended Complaint will be subject to review under 28 U.S.C. § 1915A.

Should Plaintiff file a First Amended Complaint, it is strongly recommended that he use the civil rights complaint form designed for use in this District. He should label the form “First Amended Complaint” and use the case number for this action (No. 22-1173-SMY). Plaintiff should identify each defendant in the case caption and include sufficient factual allegations against each defendant to describe what the defendant did or failed to do to violate his constitutional rights, see DiLeo v. Ernst & Young, 901 F.2d 624, 627 (7th Cir. 1990) (a successful complaint generally alleges “the who, what, when, where, and how ....”). As much as possible, Plaintiff should include the relevant facts in chronological order, inserting each defendant’s name where necessary to identify the actors and each defendant’s actions. While Plaintiff may use “John Doe” or “Jane Doe” to refer to parties whose names are unknown, he must still follow pleading standards and

include a short, plain statement of the case against that party.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Shaun J. Matz v. Rodney Klotka
769 F.3d 517 (Seventh Circuit, 2014)

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Bluebook (online)
Crawford v. Clark, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crawford-v-clark-ilsd-2023.