Dickerson v. Sangamon County State Attorney

CourtDistrict Court, C.D. Illinois
DecidedJuly 31, 2023
Docket3:23-cv-03150
StatusUnknown

This text of Dickerson v. Sangamon County State Attorney (Dickerson v. Sangamon County State Attorney) 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
Dickerson v. Sangamon County State Attorney, (C.D. Ill. 2023).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

SAMUEL DICKERSON, ) ) Plaintiff, ) ) v. ) 23-3150 ) SANGAMON COUNTY STATE’S ) ATTORNEY, et al. ) ) Defendants. )

MERIT REVIEW ORDER Plaintiff, proceeding pro se and presently detained at Sangamon County Jail, was granted leave to proceed in forma pauperis. The case is now before the Court for a merit review of Plaintiff’s claims. Plaintiff filed a Motion for Leave to File an Amended Complaint. (Doc. 4). The motion is granted. Fed. R. Civ. P. 15(a)(1). The Court will consider only those allegations in Plaintiff’s amended complaint for purposes of this Order. The Court must “screen” Plaintiff’s amended complaint, and through such process to identify and dismiss any legally insufficient claim, or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. The Court accepts the factual allegations as true, liberally construing them in the plaintiff's favor. Turley v. Rednour, 729 F.3d 645, 649 (7th Cir. 2013). Conclusory statements and labels are insufficient—the facts alleged must “state a claim for relief that is plausible on its face.” Alexander v. U.S., 721 F.3d 418, 422 (7th Cir. 2013) (citation omitted). Plaintiff alleges that he was arrested following execution of a search warrant on his residence. He alleges that Defendant Sangamon County State’s Attorney has “chosen to vindictive[ly] and selectively prosecute the Plaintiff in Bad Faith with no expectations of securing a valid conviction.” (Doc. 4 at 6). He also alleges that Defendant Sullivan, the public

defender assigned to represent him, has refused to file motions and seek evidence Plaintiff desired and that he has otherwise violated his ethical duties as a lawyer. Plaintiff alleges that both Defendants are conspiring to violate his constitutional rights. “Prosecutors are absolutely immune for actions they undertake in their capacities as prosecutors, even including malicious prosecution unsupported by probable cause.” Archer v. Chisholm, 870 F.3d 603, 612 (7th Cir. 2017); Lewis v. Mills, 677 F.3d 324, 330 (7th Cir. 2012). Public defenders are not state actors for purposes of 42 U.S.C. § 1983. Polk Cty. v. Dodson, 454 U.S. 312, 325 (1981). Plaintiff, accordingly, cannot prevail against Defendants State’s Attorney and Sullivan. Plaintiff does not make any specific allegations against Defendant Bennett, the director of the Illinois Department of Human Rights, and, therefore, the Court will dismiss this

defendant. To the extent that Plaintiff alleges Defendants State’s Attorney and Sullivan have conspired to violate his Sixth Amendment rights under Brady v. Maryland, the Court must abstain from intervening in his state court criminal proceedings. Younger v. Harris, 401 U.S. 37, 44 (1971); Mulholland v. Marion Cty. Election Bd., 746 F.3d 811, 815 (7th Cir. 2014). Plaintiff’s criminal case proceedings involve the same set of facts, are judicial in nature, implicate important state interests in enforcing their own laws, and Plaintiff will have an opportunity to present his constitutional issues in that case. If convicted, Plaintiff’s Sixth Amendment claim is properly pursued in a habeas corpus action, not an action for money damages. Preiser v. Rodriguez, 411 U.S. 475, 500 (1973) (habeas corpus is the exclusive remedy for individuals challenging a fact or duration of confinement and seeking immediate or speedier release from custody); Heck v. Humphrey, 512 U.S. 477 (1994). Plaintiff’s amended complaint is dismissed for failure to state a claim upon which relief

can be granted and because he sued individuals who are immune from suit. The Court ordinarily grants a plaintiff at least one opportunity to amend, but, given the issues presented, the Court finds that any amendment would be futile. Plaintiff’s Motion to Request Counsel (Doc. 6) 28 U.S.C. § 1915 permits the Court to “request an attorney to represent any person unable to afford counsel.” 28 U.S.C. § 1915(e)(1). The provision does not grant an indigent plaintiff a statutory or constitutional right to counsel in these types of cases, nor does it grant the Court the authority to require an unwilling attorney to represent either party. Wilborn v. Ealey, 881 F.3d 998, 1008 (7th Cir. 2018). If the case so warrants, a court can only ask a lawyer to volunteer his or her time. Id. The number of attorneys in this district willing to do so is substantially fewer

than the number of pro se plaintiffs asking for pro bono counsel. In considering the Plaintiff’s motion, the court asks: (1) has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so; and if so, (2) given the difficulty of the case, does the plaintiff appear competent to litigate it himself? Pruitt v. Mote, 503 F.3d 647, 654-55 (7th Cir. 2007). Plaintiff satisfied the first prong. The second prong requires the Court to conduct a particularized inquiry into Plaintiff’s competence and the difficulty of the case. McCaa v. Hamilton, 959 F.3d 842, 844 (7th Cir. 2020). This assessment extends beyond the trial stage of proceedings to include “the tasks that normally attend litigation: evidence gathering, preparing and responding to motions and other court filings, and trial.” Pruitt, 503 F.3d at 655. “Although there are no fixed criteria for determining whether a plaintiff is competent to litigate his own case, a district court certainly should consider the plaintiff’s literacy, communication skills, educational level, litigation experience, intellectual capacity, and psychological history.” Eagan v. Dempsey, 987 F.3d 667,

682 (7th Cir. 2021). A district court may also consider the relative strength or weakness of a plaintiff’s claims. Watts v. Kidman, 42 F.4th 755, 761 (7th Cir. 2022). Plaintiff has personal knowledge of the facts, he has adequately conveyed them to the Court, and this case does not appear to exceed his intellectual ability. Because Plaintiff appears capable of representing himself at this stage, and because he does not have a legally viable claim, Plaintiff’s motion is denied.

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Related

Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Foodcomm International v. Patrick James Barry
328 F.3d 300 (Seventh Circuit, 2003)
David L. Lewis v. Larry Mills
677 F.3d 324 (Seventh Circuit, 2012)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Zachary Mulholland v. Marion County Election Board
746 F.3d 811 (Seventh Circuit, 2014)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Cynthia Archer v. John Chisholm
870 F.3d 603 (Seventh Circuit, 2017)
Joseph Wilborn v. David Ealey
881 F.3d 998 (Seventh Circuit, 2018)
Randy McCaa v. Todd Hamilton
959 F.3d 842 (Seventh Circuit, 2020)
Shawn Eagan v. Michael Dempsey
987 F.3d 667 (Seventh Circuit, 2021)
William Watts v. Mark Kidman
42 F.4th 755 (Seventh Circuit, 2022)

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Bluebook (online)
Dickerson v. Sangamon County State Attorney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dickerson-v-sangamon-county-state-attorney-ilcd-2023.