Daniel v. Peterson

CourtDistrict Court, S.D. Illinois
DecidedAugust 19, 2025
Docket3:24-cv-01512
StatusUnknown

This text of Daniel v. Peterson (Daniel v. Peterson) 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
Daniel v. Peterson, (S.D. Ill. 2025).

Opinion

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

ASHTON DANIEL, R69925, ) ) Plaintiff, ) ) vs. ) ) Case No. 24-cv-1512-DWD JOHN PETERSON, ) DYLAN WILLIS, ) ) Defendants. )

MEMORANDUM AND ORDER

DUGAN, District Judge: Plaintiff Ashton Daniel, an inmate of the Illinois Department of Corrections (IDOC) currently incarcerated at Centralia Correctional Center (“Centralia”), brings this action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. Plaintiff alleges that in May of 2024, Defendant Peterson used excessive force against him, and Defendant Willis forcibly placed him on a hunger strike. Defendant Willis seeks summary judgment on the exhaustion of administrative remedies (Doc. 31), and Defendant Peterson moved to withdraw (Doc. 33) the affirmative defense. Plaintiff has responded (Docs. 37, 38), and Defendant Willis replied (Doc. 39). For reasons explained in this Order, Willis’ Motion (Doc. 31) is granted. BACKGROUND

This case was opened when Plaintiff filed a Motion for a Preliminary Injunction on June 14, 2024. (Doc. 1). The Court quickly informed Plaintiff that to proceed, he would need to file a proper complaint (Doc. 6), and Plaintiff complied, signing and submitting his complaint on June 28, 2024 (Doc. 11). Plaintiff alleges that problems began on May 9, 2024, when he was escorted to investigation status. (Doc. 11 at 7). He asked to see

mental health, but instead was placed on crisis watch without further consultation. While on crisis watch, Plaintiff alleges that Defendant Willis prepared a hunger strike declaration on his behalf without his permission. This forced him to miss meals for three days. (Doc. 11 at 11, 18). The Court allowed Plaintiff to proceed on a single claim against Willis related to the alleged hunger strike issue:

Claim 2: Eighth Amendment claim against Defendant Willis for placing Plaintiff on a hunger strike that he did not request, leading to the deprivation of food for 3 days.

(Doc. 19). Plaintiff was also allowed to proceed on a claim against Defendant Peterson, but Peterson withdrew the affirmative defense of failure to exhaust, so he will not be discussed further in this order. The parties undertook discovery on the exhaustion of administrative remedies, and in doing so they identified a single grievance relevant to the claim against Willis— grievance no. K7-0624-535. FINDINGS OF FACT

Plaintiff submitted grievance K7-0624-585 on May 28, 2024. (Doc. 31-1 at 9-10). In the grievance, he alleged that on May 11, 2024, he was forced on hunger strike by the first shift officer who was assigned to the crisis watch zone of the healthcare unit. He claims he asked multiple officers why he was on hunger strike and told them that he did not sign any hunger strike declaration, but they insisted he had signed and refused to help him. The grievance was marked as received for review in Plaintiff’s cumulative counseling log on June 7, 2024. (Doc. 31-2 at 2). The counseling log further reflected that

on July 15, 2024, the counselor forwarded grievance K7-0624-585 to mental health a second time for them to respond. (Doc. 31-2 at 1). Finally, on October 25, 2024, the counseling log noted that mental health answered grievance K7-0624-585, and that the counselor then returned the grievance to Plaintiff on October 28, 2024. (Doc. 31-6 at 1).

CONCLUSIONS OF LAW A. Legal Standards

Summary judgment is proper if there is no genuine issue as to any material fact and the movant is entitled to judgment as a matter of law. FED. R. CIV. P. 56(a). In determining a summary judgment motion, the Court views the facts in the light most favorable to, and draws all reasonable inferences in favor of, the nonmoving party. Apex Digital, Inc. v. Sears, Roebuck & Co., 735 F.3d 962, 965 (7th Cir. 2013) (citation omitted). Courts generally cannot resolve factual disputes on a motion for summary judgment. See Tolan v. Cotton, 572 U.S. 650, 656 (2014) (“[A] judge’s function at summary judgment is not to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.”) (internal quotation marks and citation omitted). However, when the motion for summary judgment pertains to a prisoner’s failure to

exhaust administrative remedies, the Seventh Circuit has instructed courts to conduct an evidentiary hearing and resolve contested issues of fact regarding a prisoner’s efforts to exhaust. Pavey v. Conley, 544 F.3d 739, 742 (7th Cir. 2008).1 After hearing evidence, finding facts, and determining credibility, the court must decide whether to allow the

claim to proceed or to dismiss it for failure to exhaust. Wilborn v. Ealey, 881 F.3d 998, 1004 (7th Cir. 2018). The court is not required to conduct an evidentiary hearing if there is no genuine dispute of material fact, and the determination is purely legal. See e.g., Walker v. Harris, 2021 WL 3287832 * 1 (S.D. Ill 2021). The Prison Litigation Reform Act (PLRA) provides that a prisoner may not bring a lawsuit about prison conditions unless and until he has exhausted all available

administrative remedies. 42 U.S.C. § 1997e(a); Pavey, 544 F.3d at 740. “The exhaustion requirement is an affirmative defense, which the defendants bear the burden of proving.” Pavey v. Conley, 663 F.3d 899, 903 (7th Cir. 2011). For a prisoner to properly exhaust his administrative remedies, the prisoner must “file complaints and appeals in the place, and at the time, the prison’s administrative rules require.” Pozo v. McCaughtry, 286 F.3d 1022,

1025 (7th Cir. 2002). “[A] prisoner who does not properly take each step within the administrative process has failed to exhaust state remedies.” Id. at 1024. As an inmate in the IDOC, Plaintiff was required to follow the grievance process outlined in the Illinois Administrative Code. 20 ILL. ADMIN. CODE § 504.800, et seq. (2017). An inmate must file a grievance within 60 days of an event, 20 Ill. Admin. Code §

504.810(a), and generally, a grievance officer shall make a report to the Chief

1 This case does not involve intertwinement as contemplated by Perttu v. Richards, 145 S.Ct. 1793 (2025). Administrative Officer within two months of receipt of the written grievance, when reasonably feasible, 20 Ill. Admin. Code § 504.830(e).

If the inmate is not satisfied with the CAO’s response, he can file an appeal with the IDOC Director through the Administrative Review Board (ARB). 20 ILL. ADMIN. CODE § 504.850(a). The ARB must receive the appeal within 30 days of the date of the CAO’s decision. Id. The inmate must attach copies of the responses from the grievance officer and CAO to his appeal. Id. B. Analysis

As a preliminary matter, the Court grants Defendant Willis’s Motion to Amend (Doc. 35), wherein he simply asks to tender a signed copy of a declaration from ARB chairperson John Loftus. The request was made less than a week from the filing of the motion, and it had no apparent impact on Plaintiff’s ability to respond. As to the exhaustion issue, the parties agree that just one grievance is relevant to

the claim against Willis—grievance no. K7-0624-535.

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Related

Pavey v. Conley
663 F.3d 899 (Seventh Circuit, 2011)
Pavey v. Conley
544 F.3d 739 (Seventh Circuit, 2008)
Tolan v. Cotton
134 S. Ct. 1861 (Supreme Court, 2014)
Apex Digital, Incorporated v. Sears, Roebuck & Company
735 F.3d 962 (Seventh Circuit, 2013)
Joseph Wilborn v. David Ealey
881 F.3d 998 (Seventh Circuit, 2018)
Jeremy Lockett v. Tanya Bonson
937 F.3d 1016 (Seventh Circuit, 2019)
Jonathan Chambers v. Kul Sood
956 F.3d 979 (Seventh Circuit, 2020)
Elijah Reid v. Marc Balota
962 F.3d 325 (Seventh Circuit, 2020)
Perttu v. Richards
605 U.S. 460 (Supreme Court, 2025)

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Daniel v. Peterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniel-v-peterson-ilsd-2025.