Eaton v. McConkey

District Court, S.D. Illinois·Decided November 28, 2022·No. 3:22-cv-02722·Unknown

Opinion

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

TIMOTHY DALE EATON, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-02722-JPG ) MATT McCONKEY, ) DAVID RUSSELL, ) NURSE AMBER, ) FAYETTE COUNTY SHERIFF’S OFFICE, ) and FAYETTE COUNTY JAIL, ) ) Defendants. )

MEMORANDUM AND ORDER GILBERT, District Judge: Plaintiff Timothy Dale Eaton, an inmate at Fayette County Jail (“Jail”), brings this action pursuant to 42 U.S.C. § 1983. In the Complaint, Plaintiff claims that he asked to speak with a mental health counselor on October 2, 2022, and he was told that “mental health” is not offered at the Jail. (Doc. 1, p. 5). Plaintiff wrote a grievance but received no response. He claims that this violates his constitutional rights. He includes no request for relief. (Id.). The Complaint is before the Court for review 28 U.S.C. § 1915A. Section 1915A 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 an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). Discussion Based on the allegations summarized above, the Court designates a single count in the pro se Complaint: Count 1: Eighth or Fourteenth Amendment claim against Defendants for denying Plaintiff access to mental health counseling and/or treatment at Fayette County Jail on October 2, 2022.

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. Any other claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.1 Rule 8 of the Federal Rules of Civil Procedure sets forth the general rules of pleading. Rule 8(a) requires a pleading to include “a short and plain statement of the claim showing that the pleader is entitled to relief” and “a demand for the relief sought.” FED. R. CIV. P. 8(a). Rule 8(e) requires “simple, concise, and direct” allegations in the Complaint. FED. R. CIV. P. 8(e)(1). The purpose of Rule 8 is to “give defendants fair notice of the claims against them and the grounds for supporting the claims.” Stanard v. Nygren, 658 F.3d 792, 797 (7th Cir. 2011) (citing Killingsworth v. HSBC Bank Nev., N.A., 507 F.3d 614, 618 (7th Cir. 2007); Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). The Complaint violates Rule 8 because it does not put any defendants on notice of the claims against them. Plaintiff does not mention any defendants in his statement of claim. He also sets forth no facts describing anyone’s role in a constitutional deprivation. Although Plaintiff names various jail officials as defendants in the case caption and list of defendants, merely listing

1 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face”). them as parties is insufficient to state a claim against any one of them. Plaintiff must describe what each individual did, or failed to do, to violate his rights. Moreover, it is unclear what, if any, constitutional right was violated. Plaintiff brings a claim for lack of access to “mental health” at the Jail based on the denial of a single request for

mental health counseling. The correct analytical framework for this claim hinges on his status as a pretrial detainee or convicted person when he was denied counseling. The Fourteenth Amendment’s objective unreasonableness standard governs a pretrial detainee’s claims of unconstitutional conditions of confinement and denial of medical care. Miranda v. County of Lake, 900 F.3d 335 (7th Cir. 2018). The Eighth Amendment deliberate indifference standard applies to a convicted person’s claims. See Farmer v. Brennan, 511 U.S. 825, 834 (1994); Estelle v. Gamble, 429 U.S. 97 (1976). To state a claim under both standards, Plaintiff must set forth allegations demonstrating that he suffered from some condition requiring mental health treatment in the first place and describe each defendant’s personal involvement in or responsibility for the denial of treatment. West v. Atkins, 487 U.S. 42 (1988); McCree v. Sherrod, 408 F. App’x 990 (7th Cir.

2011). In the Complaint, Plaintiff does not describe any mental health issue necessitating intervention, counseling, or treatment. He only states that the Jail offers no “mental health.” This is not enough to articulate a claim for a constitutional deprivation under the Eighth or Fourteenth Amendment. Accordingly, Count 1 shall be dismissed for failure to state a claim. The Complaint does not survive screening and shall be dismissed without prejudice. Plaintiff will have an opportunity to file a First Amended Complaint, if he wishes to pursue his claims in this case. The Court reminds Plaintiff that a successful complaint generally alleges “the who, what, when, where, and how. . . .” See DiLeo v. Ernst & Young, 901 F.2d 624, 627 (7th Cir. 1990). Thus, the First Amended Complaint should identify who violated Plaintiff’s constitutional rights by name, if known, and should include a description of how Plaintiff’s rights were violated. If Plaintiff does not know the names of these individuals, he can refer to them by Doe designation (e.g., John/Jane Doe). Additionally, Plaintiff must name each defendant in the case caption and reference him/her in the body of the First Amended Complaint.

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Related

Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Stanard v. Nygren
658 F.3d 792 (Seventh Circuit, 2011)
Rudolph Lucien v. Diane Jockisch
133 F.3d 464 (Seventh Circuit, 1998)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Killingsworth v. HSBC Bank Nevada, N.A.
507 F.3d 614 (Seventh Circuit, 2007)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
McCree v. Sherrod
408 F. App'x 990 (Seventh Circuit, 2011)