Douglas v. Jefferson County Jail

CourtDistrict Court, S.D. Illinois
DecidedOctober 10, 2025
Docket3:25-cv-01265
StatusUnknown

This text of Douglas v. Jefferson County Jail (Douglas v. Jefferson County Jail) 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
Douglas v. Jefferson County Jail, (S.D. Ill. 2025).

Opinion

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

KEONTA DOUGLAS, #167137, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-01265-JPG ) JEFFERSON COUNTY JAIL, ) NURSE JASON, ) NURSE TERRY, ) CAPTAIN MAY, ) LT. GARCIA, ) C/O JOHN DOE 1, ) and DR. JOHN DOE 2, ) ) Defendants. )

MEMORANDUM AND ORDER GILBERT, District Judge: Plaintiff Keonta Douglas filed this civil rights action pursuant to 42 U.S.C. § 1983 for constitutional deprivations that occurred during his detention at Jefferson County Justice Center located in Mount Vernon, Illinois. In the Complaint, Plaintiff alleges that he suffered an ankle injury when he had a seizure and fell from his top bunk. (Doc. 1). He claims the injury could have been avoided with a low bunk assignment. Plaintiff seeks money damages. Id. The Complaint is now subject to preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from a defendant who is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). At this stage, the factual allegations in the pro se complaint are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 1, pp. 6-8): When he arrived at Jefferson County Justice Center on January 17, 2025,1 Plaintiff told C/O John Doe 1 about his diagnosis with a seizure disorder, his treatment with medication, and his need for a bottom bunk. Id. at 6. Plaintiff reported the same thing to Nurse Jason, who instructed him to

provide this information to Dr. John Doe 2. Id. C/O John Doe 1 then took Plaintiff to K Block. Plaintiff again stated that he needed a bottom bunk for his seizure disorder, and the correctional officer told him to “find one” in K Block. Id. at 6-7. No inmates would give the plaintiff a bottom bunk. Id. at 7. During his medical intake four days later, Plaintiff met with Nurse Terry and Dr. John Doe 2. Plaintiff’s prescription medication for his seizure disorder was verified and documented,2 but he was not given a bottom bunk permit. Id. Plaintiff repeatedly asked the nurses for a bottom bunk when attending pill line. Nurses Jason and Terry told Plaintiff that the Jail had his prison medical records and they would “look into it.” Id. Nothing changed. On March 25, 2025, Plaintiff

filed a grievance to complain about the fall risk posed by his top bunk assignment. Id. Captain May issued a “final response” saying, “Lt. Garcia is working on it. Did you tell [the] C/O who brought you in?” Id. The same day, Plaintiff suffered a seizure and fell from his top bunk. Id. He sustained injuries that required an overnight stay in the hospital. Plaintiff was diagnosed with a sprained ankle and released the next day. When he returned to the Jail, Plaintiff was finally assigned a bottom bunk on March 26, 2025. Id. at 8.

1 Plaintiff alleges that he faced federal charges while housed at the Jail. 2 Plaintiff does not allege that he was denied prescription medication for his seizure disorder or that there was a lapse in medication. Plaintiff submitted several written requests for pain medication for his ankle. These requests were dated March 29, April 10, April 28, May 8, May 9, May 27, and May 28. In response, Plaintiff received Motrin/ibuprofen. Id. He complains that the Jail’s grievance process requires submission of complaints at a kiosk, and a “final response” is typically issued by the subject of the grievance. Id. at 9. No third-party

counselor, grievance officer, director, or sheriff considers an appeal. Plaintiff claims that his injuries might have been avoided if the Jail made use of a meaningful grievance process. Id. Preliminary Dismissal Jefferson County Justice Center is named as a defendant, but the Jail is not considered a person or policy-making body that is subject to suit under 42 U.S.C. § 1983. Smith v. Knox County Jail, 666 F.3d 1037, 1040 (7th Cir. 2012). Because it is not a suable entity, this defendant shall be dismissed with prejudice. Discussion Based on the allegations summarized herein, the Court designates the following claims in

the pro se Complaint: Count 1: Fourteenth or Eighth Amendment claim against Defendants for denying Plaintiff a low bunk at the Jail from January 17, 2025 until March 25, 2025, resulting in his fall from the top bunk while having a seizure on or around March 25, 2025.

Count 2: Fourteenth or Eighth Amendment claim against Defendants for denying Plaintiff adequate medical care for pain caused by a sprained ankle he sustained at the Jail on or around March 25, 2025.

Count 3: Fourteenth Amendment claim against Defendants for their failure to adopt or implement a meaningful grievance process at the Jail in 2025.

The parties and the Court will use these designations in all future pleadings and orders, unless otherwise directed by a judicial officer of this Court. Count 1 If Plaintiff was a pretrial detainee when his claims arose, the Fourteenth Amendment Due Process Clause governs his claim for unconstitutional conditions of confinement. Hardeman v. Curran, 933 F.3d 816, 821-22 (7th Cir. 2019) (citing Kingsley v. Hendrickson, 576 U.S. 389, 397 (2015)). Under the Fourteenth Amendment, a plaintiff must show that he faced a serious

deprivation and that each defendant responded in a manner that was “objectively unreasonable,” was not “rationally related to a legitimate non-punitive governmental purpose,” or “was excessive in relation to that purpose.” Kemp v. Fulton Cty., 27 F.4th 491, 495 (7th Cir. 2022) (citing Hardeman, 933 F.3d at 822, 824). If Plaintiff was already convicted of a crime at the time this claim arose, the Eighth Amendment controls and requires the plaintiff to set forth allegations of deliberate indifference by each defendant to the serious risk of harm posed to his health or safety. See Withers v. Wexford Health Sources, Inc., 710 F.3d 688, 689 (7th Cir. 2013). Plaintiff alleges that he repeatedly informed staff about his seizure disorder and the need for a low bunk to prevent injuries beginning January 17, 2025. However, C/O John Doe 1, Nurse

Terry, Nurse Jason, and Dr. John Doe 2 disregarded his requests for a low bunk until after he fell from his top bunk during a seizure and injured his ankle on March 25, 2025. These allegations suggest that each defendant responded to a serious risk of injury to the plaintiff in a manner that was objectively unreasonable and/or deliberately indifferent. Count 1 survives screening as a Fourteenth Amendment or Eighth Amendment claim against C/O John Doe 1, Nurse Terry, Nurse Jason, and Dr. John Doe 2.

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Related

Anthony N. Smith v. Knox County Jail
666 F.3d 1037 (Seventh Circuit, 2012)
Withers v. Wexford Health Sources, Inc.
710 F.3d 688 (Seventh Circuit, 2013)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Grieveson v. Anderson
538 F.3d 763 (Seventh Circuit, 2008)
Shaun J. Matz v. Rodney Klotka
769 F.3d 517 (Seventh Circuit, 2014)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Tapanga Hardeman v. David Wathen
933 F.3d 816 (Seventh Circuit, 2019)
Gregory Kemp v. Fulton County, Illinois
27 F.4th 491 (Seventh Circuit, 2022)

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Douglas v. Jefferson County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/douglas-v-jefferson-county-jail-ilsd-2025.