Dawson v. Hughes

CourtDistrict Court, S.D. Illinois
DecidedOctober 7, 2025
Docket3:25-cv-00742
StatusUnknown

This text of Dawson v. Hughes (Dawson v. Hughes) 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
Dawson v. Hughes, (S.D. Ill. 2025).

Opinion

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

KEVIN DAWSON, # M53531, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-00742-SMY ) LATOYA HUGHES, ) JOLEEN KUHNERT, ) FRANK LAWRENCE, and ) ANTHONY WILLS, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Kevin Dawson, an inmate of the Illinois Department of Corrections (“IDOC”) currently incarcerated at Menard Correctional Center, filed the instant lawsuit pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. Plaintiff is wheelchair-bound and claims he was denied necessary accommodations, in violation of the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq. and the Rehabilitation Act (“RA”), 29 U.S.C. § 701, et seq. (Doc. 1). He seeks monetary damages and injunctive relief. Id. This case is now before the Court for preliminary review of the Complaint under 28 U.S.C. § 1915A, which requires the Court to screen prisoner Complaints to filter out nonmeritorious claims. 28 U.S.C. § 1915A(a). 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): Plaintiff is a qualified individual under the ADA and RA who depends on a wheelchair due to a gunshot wound to his spinal cord (Doc. 1, pp. 10, 13, 16). On June 5, 2024, he was transferred to Menard and placed in the health care unit, which lacked grab/assist bars to assist him with maneuvering in and out of his wheelchair (Doc. 1, p. 10).

On August 23, 2024, Plaintiff was moved to cell No. 311, which was also not ADA compliant with no assist bars. The toilet was too low, had no bars, and Plaintiff was forced to use it backwards (Doc. 1, p. 12). The sink was attached to the toilet, making it hard for Plaintiff to use. The shower was difficult to access, and the shower chair was broken. After Plaintiff filed a grievance, Defendant Joleen Kuhnert (the Assistant ADA Coordinator) spoke to him on August 30, 2024 (Doc. 1, pp. 10, 12, 14). Kuhnert listened to Plaintiff’s explanation of the problems and observed the shower but took no action to provide Plaintiff with necessary accommodations for his safety. Id. On January 13, 2025, Plaintiff was using the shower chair when it broke, causing him to fall and hit his head. He is unable to fit his wheelchair into the shower. Plaintiff filed another

grievance in January 2025. He has suffered other falls since that date (Doc. 1, p. 18). IDOC has failed to provide Plaintiff with safe and accessible toileting facilities, showering facilities, housing, or basic hygiene facilities at Menard and has failed to provide him with any reasonable accommodations for his disability (Doc. 1, pp. 13-14). As a result of Kuhnert’s and IDOC’s failure to provide these accommodations, Plaintiff has been injured in falls, has suffered difficulty with his bowels and bodily functions, and has experienced severe pain and suffering (Doc. 1, pp. 15, 17-18). Plaintiff seeks damages, and injunctive relief requiring the IDOC to provide him with facilities and accommodations in compliance with the ADA and RA (Doc. 1, pp. 16, 18, 20). Based on the allegations in the Complaint, the Court designates the following claims in this pro se action: Count 1: ADA and RA claims against Defendants for failing to provide wheelchair-accessible facilities and accommodations for Plaintiff’s disability.

Count 2: Eighth Amendment claim against Defendants for their deliberate indifference to Plaintiff’s serious medical and disability-related needs, resulting in injury, pain, and suffering.

Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard. See Bell Atlantic 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.”). Preliminary Dismissals Plaintiff names Frank Lawrence, the assistant warden and ADA coordinator, as a defendant (Doc. 1, p. 2). However, he fails to mention Lawrence in his statement of claim and does not describe what he allegedly did to violate his constitutional rights. (Doc. 1, pp. 2-3, 10-18). Merely invoking the name of a potential defendant is not sufficient to state a claim against that individual. See Collins v. Kibort, 143 F.3d 331, 334 (7th Cir. 1998). Because Plaintiff has not articulated a claim against Lawrence, he will be dismissed from the case without prejudice. Discussion Count 1 Plaintiff's allegations are sufficient to state a viable ADA and RA claim. However, this claim cannot proceed against the individual employees of IDOC because they cannot be sued under the ADA or the RA. Jaros v. Illinois Dep't of Corrs, 684 F.3d 667, 670 (7th Cir. 2012). The proper defendant is the relevant state department or agency. See 42 U.S.C. § 12131(1)(b); Jaros, 684 F.3d at 670, n. 2 (individual capacity claims are not available; the proper defendant is the agency or its director (in their official capacity)). Plaintiff has correctly named Latoya Hughes (IDOC Director) as a defendant in her official capacity. Therefore, Count 1 will proceed only

against Hughes; the remaining defendants are dismissed from this claim. Count 2 Prison officials violate the Eighth Amendment’s prohibition against cruel and unusual punishment when they act with deliberate indifference to a prisoner’s serious medical needs. Rasho v. Elyea, 856 F.3d 469, 475 (7th Cir. 2017). To state such a claim, a prisoner must plead facts suggesting that (1) he suffered from an objectively serious medical condition, and (2) the defendant acted with deliberate indifference to his medical needs. Id. An objectively serious condition includes a condition that significantly affects an individual’s daily activities or which involves chronic and substantial pain. Gutierrez v. Peters, 111 F.3d 1364, 1373 (7th Cir. 1997). While Plaintiff did not specifically invoke the Eighth Amendment, he seeks monetary

damages for the injuries he suffered from the lack of ADA/RA safety accommodations. Plaintiff’s allegation that Joleen Kuhnert knew about the danger he faced from the noncompliant conditions yet failed to act to mitigate the risks is sufficient to state a claim for deliberate indifference against her. Count 2 will therefore proceed against Kuhnert in her individual capacity. The remaining defendants are dismissed from this claim.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Gonzalez v. Feinerman
663 F.3d 311 (Seventh Circuit, 2011)
Jaros v. Illinois Department of Corrections
684 F.3d 667 (Seventh Circuit, 2012)
Ashoor Rasho v. Willard Elyea
856 F.3d 469 (Seventh Circuit, 2017)

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Bluebook (online)
Dawson v. Hughes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dawson-v-hughes-ilsd-2025.