Crump v. State of Illinois

CourtDistrict Court, S.D. Illinois
DecidedJanuary 11, 2024
Docket3:23-cv-01922
StatusUnknown

This text of Crump v. State of Illinois (Crump v. State of Illinois) 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
Crump v. State of Illinois, (S.D. Ill. 2024).

Opinion

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

STEVEN CRUMP, ) Y20690, ) ) Plaintiff, ) ) vs. ) ) Case No. 23-CV-1922-DWD ) JOHN DOE 2 (Menard parole processor), ) WARDEN OF MENARD, ) JANE DOES 1-4, ) JOHN DOE 5 (VIENNA RECORDS ) DEPT. OFFICER), ) WARDEN OF VIENNA, ) ) Defendants. )

MEMORANDUM AND ORDER

DUGAN, District Judge: Plaintiff Steven Crump, a former inmate1 of the Illinois Department of Corrections (IDOC), brings this civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. (Doc. 17). Plaintiff alleges that he was held at least 30 days beyond the expiration of his Mandatory Supervised Release (MSR). He alleges that the Defendants were responsible for this extended period of detention, and he seeks monetary compensation for each day he spent detained beyond his MSR. Upon initial review of his Amended Complaint, the Court allowed Plaintiff to proceed against John Doe 2, an officer whom he alleged he interacted with upon intake at Menard, and whom

1 Plaintiff was detained for an alleged parole violation at the time he filed this lawsuit on June 1, 2023, but he now avers in his amended complaint that he was released on June 15, 2023. His current mailing address is that of a County Sheriff’s Department in Kansas, which suggests he may be detained again. he alleged failed to remedy his sentence miscalculation. Plaintiff now seeks to further amend his complaint to add individuals at Vienna Correctional Center (Vienna) whom

he alleges also failed to remedy his sentence issues. (Doc. 29). Plaintiff’s proposed amendment (Doc. 29) is now before the Court for preliminary review pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a)- (b). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by

law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations of the pro se complaint are to be liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Motion to Amend Rather than file a comprehensive amended complaint, Plaintiff has filed a short

two-page “motion” to amend wherein he describes the parties that he seeks to add as defendants. While the Court generally does not accept “piecemeal” amendments such as this motion, the involvement of the additional defendants was already described in the First Amended Complaint. (Doc. 17). Plaintiff alleged in his First Amended Complaint that once he arrived at Menard,

staff did not enter his information into the system, and they did not inform the parole board of his location. As a result, he missed two parole hearings. (Doc. 17 at 4). Eventually he was sent to Vienna Correctional Center where administrators knew nothing about him or his reason for being sent there. He was informed by case managers at Vienna that Menard had messed up his paperwork.

Plaintiff was eventually seen by the parole board; at which time he was informed that he should not have been violated or arrested. (Doc. 17 at 4-5). He avers that he completed 3 years and 10 months of parole out of a 4-year term, and he had satisfied all stipulations of his parole. The parole board told him that he could no longer be reinstated on parole because his term of parole was over. They approved the parole violation and assessed his situation as ‘time served.’ As soon as the Vienna administration processed

the paperwork, he was released on June 15, 2023, 30 days after his MSR date. In the Motion to Amend (Doc. 29), Plaintiff now seeks to identify an official at Vienna who is the “man who runs the records dept. and calculates time served.” (Doc. 29 at 2). He refers to this individual as John Doe 5 and he alleges that this individual acknowledged that his release date had been miscalculated when they met face-to-face,

but this man did not act to correct the miscalculation and instead allowed him to remain confined at least 15 days beyond his release date of May 15, 2023. Plaintiff also seeks to add Jane Does 1-4. He alleges that these women made up the Parole Board Hearing Committee. He alleges that these individuals conspired to alter his time served records to “cover up” the time he was kept in custody beyond his mandatory release date of May

15, 2023. To help identify these five individuals, Plaintiff also asks to add the Warden of Vienna. Based on the allegations in the Motion to Amend (Doc. 29), the Court will designate the following additional claim: Count 1: Eighth Amendment deliberate indifference or Fourteenth Amendment substantive due process claim against Jane Does 1-4, and John Doe 5 for their roles in holding Plaintiff 30 days beyond his MSR date from May 15, 2023, to June 15, 2023.

The parties and the Court will use this designation in all future pleadings and orders unless otherwise directed by a judicial officer of this Court. Any claim that is mentioned in the Complaint but not addressed in this Order is considered dismissed without prejudice as inadequately pled under Twombly. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim that is plausible on its face”). Analysis Plaintiff will be allowed to proceed on Claim 2 against Defendants Jane Doe 1-4 and John Doe 5. It is clear that an inmate can proceed under the Eighth Amendment for being detained longer than he should be by the deliberate indifference of an official, Childress v. Walker, 787 F.3d 433, 439 (7th Cir. 2015), and such a claim might also sound under substantive due process, Courtney v. Butler, 756 Fed. App’x 626, 627 (7th Cir. 2019). The Warden of Vienna will be added to this lawsuit in his or her official capacity for the sole purpose of helping Plaintiff to identify Jane Does 1-4 and John Doe 5. To this end, within 30 days of this Order, Plaintiff should file a Notice with the Court that provides any identifying information he has about Jane Does 1-4 and John

Doe 5, such as if he received documents signed by this person, if he ever spoke with them or attempted to contact them, or if they were identified in any grievance documentation. He should also provide a physical description of these individuals. The Warden of Vienna will then be required to respond to this Notice with any information that he or she possesses that might help to identify Jane Does 1-4 or John Doe 5.

Motions Plaintiff has essentially filed two Motions for Counsel (Docs. 25, 28). In the first Motion (Doc. 25) he seeks referral to local pro bono attorneys. In the second Motion (Doc. 28), Plaintiff explicitly requests the appointment of counsel on the premise that he is incarcerated, knows very little about the applicable law, and is disadvantaged relative to the defendants. There is no right to the appointment of counsel in civil matters. Romanelli

v. Suliene,

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Romanelli, Ronald v. Suliene, Dalia
615 F.3d 847 (Seventh Circuit, 2010)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Craig Childress v. Roger Walker, Jr.
787 F.3d 433 (Seventh Circuit, 2015)

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Crump v. State of Illinois, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crump-v-state-of-illinois-ilsd-2024.