Crayton v. Gerischer

CourtDistrict Court, C.D. Illinois
DecidedJanuary 19, 2024
Docket4:22-cv-04022
StatusUnknown

This text of Crayton v. Gerischer (Crayton v. Gerischer) 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
Crayton v. Gerischer, (C.D. Ill. 2024).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

KEIMON CRAYTON, ) ) Plaintiff, ) ) v. ) 22-4022 ) CAMERON GERISCHER, et al. ) ) Defendants. )

SUMMARY JUDGMENT ORDER Plaintiff, proceeding pro se and presently incarcerated at Pickneyville Correctional Center, brought the present lawsuit pursuant to 42 U.S.C. § 1983 alleging Fourteenth Amendment claims arising from his detention at Rock Island County Jail. The matter comes before this Court for ruling on the Defendant O’Melia’s Motion for Summary Judgment, Plaintiff’s Motion for Leave to File Summary Judgment, Plaintiff’s Motions for Summary Judgment, and Plaintiff’s Motion for Leave to File an Amended Complaint. (Docs. 154, 156, 158, 159, 162, 164). PRELIMINARY MATTERS Plaintiff’s Motion for Leave to File an Amended Complaint (Doc. 162) Plaintiff seeks leave to file an amended complaint to correct a factual error and to reiterate the amount of damages he is seeking. Plaintiff did not attach a proposed amended complaint to his motion as required by the Court’s Scheduling Order and as instructed in the Court’s orders on Plaintiff’s previous motions seeking the same relief. See (Docs. 108, 112); Text Order entered Feb. 2, 2023. Plaintiff’s motion is denied. SUMMARY JUDGMENT STANDARD Summary judgment should be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). All facts must be construed in the light most favorable to the non-moving party,

and all reasonable inferences must be drawn in his favor. Ogden v. Atterholt, 606 F.3d 355, 358 (7th Cir. 2010). The party moving for summary judgment must show the lack of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). In order to be a “genuine” issue, there must be more than “some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). DEFENDANT O’MELIA’S MOTION FOR SUMMARY JUDGMENT (DOC. 154) The Court’s Merit Review Order #2 found that Plaintiff stated a Fourteenth Amendment procedural due process claim against Defendant O’Melia based on Plaintiff’s allegations that this

defendant placed him in more restrictive confinement for no reason. (Doc. 50 at 1-2). Defendant O’Melia moves for summary judgment. Facts Plaintiff was a detainee at the Rock Island Jail (“jail”). On October 19, 2021, jail officials housed Plaintiff in P Block, an area reserved for detainees charged with or convicted of sex crimes, after the Rock Island State’s Attorney charged Plaintiff criminal sexual assault and criminal sexual abuse. (Doc. 154-1 at 7); (Doc. 154-3). Jail officials house detainees so charged separately from other general population detainees because they believe the nature of these crimes subjects the detainees to a greater risk of assault. (Doc. 154-5 at 2, ¶¶ 12-14). Between October 19-21, 2021, jail officials received information that a “feud” had developed between Plaintiff and other individuals housed on P Block. (Doc. 154-5 at 3, ¶¶ 20- 21). On October 23, 2021, Plaintiff submitted a request via the electronic kiosk stating, “Racist Deck. Im just protecting myself. It was stated this is a racist deck.” (Doc. 154-2 at 5). He

submitted another request two minutes later stating, “If he steal my tray I have to defend myself.” Id. According to requests Plaintiff submitted two days later, the latter request referenced an incident where another inmate tried to fight him in P Block. (Doc. 154-2 at 5) (“[I]t was a group who tried to fight me the leader said he was gone kill me and his soldiers agreed with him.”). Based on this information, jail officials reassigned Plaintiff on October 23, 2021, to a segregative housing unit used to house detainees that needed to be kept separate from other inmates, either for disciplinary reasons or for protection from other detainees. (Doc. 154-1 at 7); (Doc. 154-5 at 1-2, ¶¶ 8-9). Defendant O’Melia escorted Plaintiff to the new cell block the same day; he was not involved in the decision to reassign Plaintiff. (Doc. 154-6 at 1, ¶¶ 5-7); (Doc.

156-1 at 9, ¶ 20). Plaintiff did not receive a hearing prior to the move, nor had he been accused of violating a prison rule. Analysis Plaintiff does not have a constitutional right to be housed in a specific housing unit or one of his choosing. Jamal v. Cuomo, 234 F.3d 1273, 1273 (7th Cir. 2000); Williams v. Faulkner, 837 F.2d 304, 309 (7th Cir. 1988). The additional restrictions Plaintiff allegedly faced following his transfer to a segregative housing unit implicates procedural due process concerns only if those restrictions amounted to an “atypical and significant” deprivation in relation to the “ordinary incidents” of pretrial confinement. Sandin v. Conner, 515 U.S. 472, 484 (1995); Miller v. Dobier, 634 F.3d 412, 415-16 (7th Cir. 2011) (“Disciplinary measures that do not substantially worsen the conditions of confinement of a lawfully confined person are not actionable under the due process clause.”). Plaintiff’s main complaint appears to be that he did not have access to a television or other privileges while so housed. E.g., (Doc. 157 at 1) (“[S]eg. restricts an inmate’s

privileges,” such as dayroom, tv/tablets); (Doc. 154-2 at 5) (responding to a grievance officer’s question about whether Plaintiff wanted to be housed in protective custody, “if it has a TV yes.”). Access to those items in other housing units does not permit a reasonable inference that the conditions he endured while housed in segregation amounted to the deprivation required to trigger procedural protections of the Fourteenth Amendment. To the extent that Plaintiff challenges the decision to house him in segregation, the record does not permit a reasonable inference that Defendant O’Melia was personally involved in the decision to reassign Plaintiff, and, absent such a showing, Plaintiff cannot hold Defendant O’Melia liable. 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.”). Notwithstanding Defendant O’Melia’s lack of involvement, the record does not permit a reasonable inference that moving Plaintiff to a cell block that did not present the risks of harm Plaintiff faced in other housing units was objectively unreasonable—this decision falls squarely within the types of decisions for which the Court must afford deference to jail officials. See Mays v. Dart, 974 F.3d 810, 821 (7th Cir.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Ogden v. Atterholt
606 F.3d 355 (Seventh Circuit, 2010)
Miller v. Dobier
634 F.3d 412 (Seventh Circuit, 2011)
Harry Lawrence Williams, Sr. v. Gordon H. Faulkner
837 F.2d 304 (Seventh Circuit, 1988)
Candis Flint v. City of Belvidere
791 F.3d 764 (Seventh Circuit, 2015)
Carlos Bowman v. Jeffrey Korte
962 F.3d 995 (Seventh Circuit, 2020)
Anthony Mays v. Thomas Dart
974 F.3d 810 (Seventh Circuit, 2020)

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Bluebook (online)
Crayton v. Gerischer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crayton-v-gerischer-ilcd-2024.