Fejerang v. G. T. L.

CourtDistrict Court, S.D. Illinois
DecidedOctober 10, 2023
Docket3:23-cv-01283
StatusUnknown

This text of Fejerang v. G. T. L. (Fejerang v. G. T. L.) 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
Fejerang v. G. T. L., (S.D. Ill. 2023).

Opinion

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

JUSTIN FEJERANG, #Y28680, ) ) Plaintiff, ) vs. ) Case No. 23-cv-01283-SMY ) G.T.L., ) ROB JEFFREYS, and ) ANTHONY D. WILLS, ) ) Defendants. )

MEMORANDUM AND ORDER

YANDLE, District Judge: Plaintiff Justin Fejerang, 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. He raises claims of false advertising, breach of contract, and violation of his Fourteenth Amendment Due Process rights related to his purchase of an electronic tablet and seeks monetary damages and an order to “allow [him] his right to use the whole tablet” including all advertised features and apps (Doc. 1). 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 his Complaint (Doc. 1): Plaintiff bought a tablet from Defendant G.T.L. that was advertised to guarantee access to unlimited music, books, news feeds, movies, games, phone, videos, and emojis (Doc. 1, p. 2). However, Defendants Jeffreys and Wills, without any penological justification, made 30 out of the 40 advertised apps unavailable. Jeffreys has a contract with G.T.L. to sell tablets to inmates, and Jeffreys and Wills have a

contract with Plaintiff because he purchased the tablet. G.T.L. in turn has a contract (displayed on the tablet) with Plaintiff and other prisoners who buy the device. Jeffreys and Wills maintain “confiscation sheet” procedures that satisfy prisoners’ due process rights when they buy a product from an outside company. The procedure allows the prisoner to direct the confiscated item to be sent home, picked up at the prison, or destroyed, when they are not allowed to possess the property item. Plaintiff’s tablet has a support app that records the funds placed on the tablet and how they are spent for items featured on the tablet.1 He attempted to access music only to find certain music was unavailable despite the “unlimited music” guarantee. The tablet would display an error message that data could not be received from the server – but in fact, Wills and Jeffreys had

restricted access to some music. Plaintiff experienced a similar problem when trying to access books; the tablet would display “book not found.” Wills and Jeffreys had restricted Plaintiff’s access and removed advertised books. They also removed the news feed app and certain emojis.2 Plaintiff sues each Defendant in their individual and official capacity. Based on the allegations in the Complaint, the Court designates the following claims in this pro se action: Count 1: False advertising/consumer fraud claim against all Defendants for

1 Plaintiff notes he wants to use his tablet as evidence to show his purchases/transactions. 2 As examples, a James Patterson novel is approved on the IDOC publication review list but is restricted on the tablet. Certain song lyrics can be sent to inmates through the mail, but tablet access is blocked. Plaintiff paid for games, movies, and other tablet items that were removed and restricted without penological justification. failing to provide the promised unlimited access to books, music, and other items on the G.T.L. tablet.

Count 2: Breach of contract claim against all Defendants for failing to provide the promised unlimited access to books, music, and other items on the G.T.L. tablet.

Count 3: Fourteenth Amendment due process claim against Jeffreys and Wills for restricting Plaintiff’s access to certain music, books, movies, games, and other apps on his tablet without penological justification.

Count 4: First Amendment claim against Jeffreys and Wills for restricting Plaintiff’s access to certain music, books, movies, games, and other apps on his tablet without penological justification.

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.3 Discussion Count 1 Plaintiff’s “false advertising” claim is not a federal constitutional claim. It may best be characterized as a consumer fraud claim, which could be brought under the Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILL. COMP. STAT. 505/2. See Flournoy v. Ameritech, 814 N.E.2d 585, 588-89 (Ill. App. 2004) (“To state a private cause of action under the Consumer Fraud Act, the plaintiff must allege: (1) a deceptive act or practice by the defendant; (2) that the defendant intended for the plaintiff to rely on the deception; (3) that the deception occurred in the conduct of a trade or commerce; (4) that the plaintiff suffered actual damages; and (5) that the damages were proximately caused by the deceptive conduct.”) (citing Oliveira v. Amoco Oil Co., 776 N.E.2d 151 (Ill. 2002)).

3 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.”). Where a district court has original jurisdiction over a civil action such as a § 1983 claim, it also has supplemental jurisdiction over related state law claims pursuant to 28 U.S.C. § 1367(a), so long as the state claims “derive from a common nucleus of operative fact” with the original federal claims. As discussed below, the First Amendment claim in Count 4 survives threshold

review. Count 1 is grounded on the same operative facts as Count 4 and may therefore proceed for further consideration in this case. Count 2 A claim for breach of contract arises under state law and does not implicate the Constitution. As with Count 1 above, Plaintiff’s contract claim may proceed in this § 1983 action only if it is based on a “common nucleus” of facts with a federal constitutional claim. Count 2 is sufficiently related to the First Amendment claim in Count 4, and may also proceed under the Court’s supplemental jurisdiction. Count 3 Plaintiff’s allegations do not support a Fourteenth Amendment due process claim for the

alleged “taking” of his property interest. Plaintiff suggests that his due process rights were violated because Defendants did not follow the “confiscation sheet” notice and response procedure before curtailing Plaintiff’s access to the blocked apps and content on his tablet. However, the failure to follow that procedure does not constitute a constitutional violation. A federal court does not enforce state law or a prison regulation such as this. Archie v. City of Racine, 847 F.2d 1211, 1217 (7th Cir. 1988) (en banc), cert.

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Fejerang v. G. T. L., Counsel Stack Legal Research, https://law.counselstack.com/opinion/fejerang-v-g-t-l-ilsd-2023.