Eguia v. David Gladieux

District Court, N.D. Indiana·Decided November 8, 2022·No. 1:22-cv-00168·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

ADRIAN EGUIA,

Plaintiff,

v. CAUSE NO. 1:22-CV-168-DRL-SLC

DAVID GLADIEUX,

Defendant.

OPINION AND ORDER Adrian Eguia, a prisoner without a lawyer, filed a complaint against Allen County Sheriff David Gladieux seeking damages for being held in the unconstitutional conditions of confinement at the Allen County Jail identified in Morris v. Sheriff of Allen County, No. 1:20-CV-34-DRL, 2022 WL 971098 (N.D. Ind. Mar. 31, 2022). ECF 1. The court determined the complaint did not state a claim because Mr. Eguia did not allege how he was personally injured by the conditions. ECF 5. Mr. Eguia has now filed an amended complaint about several different aspects of his confinement. ECF 11. “A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted). Nevertheless, under 28 U.S.C. § 1915A, the court must review the merits of a prisoner complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. First, Mr. Eguia alleges he spent more than two years—765 days to be exact—at the Allen County Jail in overcrowded conditions. Upon intake, he says that for seven

days, from June 12-19, 2020, he was not provided with any hygiene materials or allowed to shower. Then, he was moved to quarantine block 6-A, where he was placed in an overcrowded 6-person cell for fourteen days. In that time, he claims he had to sleep on the floor near the toilet. In addition, he contends he was allowed only a five-minute shower every three days, and was not given the opportunity to spend an hour a day outside of his cell.

After his quarantine period ended, Mr. Eguia alleges he was placed in 6-C Block. Here, he claims he was the third person in a two-person cell and again had to sleep on the floor near the toilet. He says he would get woken up at night when a cellmate had to use the toilet. Mr. Eguia alleges that throughout his entire two-year detention, he was not offered recreation. Mr. Eguia emphasizes how stressful these conditions were. He says it

is hard to be going through a criminal trial with no way to escape your problems or to “shake off bad energy” because the crowded conditions allow for no privacy. ECF 11 at 3. Because Mr. Eguia was a pretrial detainee while at the Allen County Jail, his rights arise under the Fourteenth Amendment. Miranda v. Cnty. of Lake, 900 F.3d 335, 352 (7th

Cir. 2018) (citing Kingsley v. Hendrickson, 576 U.S. 389 (2015)). “[T]he Fourteenth Amendment’s Due Process Clause prohibits holding pretrial detainees in conditions that ‘amount to punishment.’” Mulvania v. Sheriff of Rock Island Cnty., 850 F.3d 849, 856 (7th Cir. 2017) (citation omitted). To state a claim that a jail policy violates the Fourteenth Amendment, a plaintiff must allege that a resulting pretrial condition “is ‘imposed for the purpose of punishment,’ or . . . the condition ‘is not reasonably related to a legitimate

goal—if it is arbitrary or purposeless . . ..’” Id. at 856 (quoting Bell v. Wolfish, 441 U.S. 520, 538-39 (1979). Courts consider whether “the challenged governmental action is not rationally related to a legitimate governmental objective or [whether] it is excessive in relation to that purpose.” Id. (quoting Kingsley, 576 U.S. at 398). Overcrowding, on its own, does not state a constitutional claim; instead the court must look to the effects the overcrowding has on the conditions of confinement. See Bell

v. Wolfish, 441 U.S. 520, 541 (1979) (“While confining a given number of people in a given amount of space in such a manner as to cause them to endure genuine privations and hardship over an extended period of time might raise serious questions under the Due Process Clause as to whether those conditions amounted to punishment, nothing even approaching such hardship is shown by this record.”); see also Hubbard v. Taylor, 538 F.3d

229 (3d Cir. 2008) (after determining that the triple-celling of pretrial detainees was rationally related to managing an overcrowded facility, the court turned to “whether these conditions cause inmates to endure such genuine deprivations and hardship over an extended period of time, that the adverse conditions because excessive in relation to the purposes assigned to them” (quotation marks omitted)). For example, overcrowding

could lead to deprivations of essential food, medical care, or sanitation, cause an increase in violence, or result in other intolerable prison conditions. Rhodes v. Chapman, 452 U.S. 337, 348 (1981). Here, Mr. Eguia plausibly alleges that spending two years in overcrowded conditions, coupled with the lack of recreation, could amount to punishment. Cf. James v.

Pfister, 708 F. Appx. 876, 879 (7th Cir. 2017) (“Our decisions are clear that preventing inmates from exercising for prolonged periods may violate the Eighth Amendment.”); Gray v. Hardy, 826 F.3d 1000, 1005 (7th Cir. 2016) (“An adverse condition of confinement, if endured over a significant time, can become an Eighth Amendment violation even if it would not be impermissible if it were only a short-term problem.”). The psychological stress he endured can be considered an injury for purposes of 42 U.S.C. § 1983. See

Mulvania, 850 F.3d at 855-58 (allegation that being denied underwear was “humiliating” stated cognizable harm under Fourteenth Amendment). A lack of a physical injury, however, may affect the damages he may ultimately recover. See Thomas v. Illinois, 697 F.3d 612, 614 (7th Cir. 2012) (“[Under 42 U.S.C. § 1997e(e),] a prisoner cannot obtain compensatory damages without proving a physical injury.”). Nevertheless, because

Mr. Eguia describes a practice or custom of denying recreation to inmates living in overcrowded conditions, he may proceed against Sheriff Gladieux in his official capacity on a Fourteenth Amendment claim. See Budd v. Motley, 711 F.3d 840, 843-44 (7th Cir. 2013) (concluding plaintiff stated only an official capacity claim concerning alleged poor jail conditions because he “describe[ed] a municipal practice or custom in running the jail,

rather than the Sheriff’s personal conduct”). Next, Mr. Eguia complains about limitations on his ability to practice his religion at the jail. Inmates retain their right under the First Amendment to practice their religion. Kaufman v. McCaughtry, 419 F.3d 678, 681 (7th Cir. 2005).

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