French v. Wills

CourtDistrict Court, S.D. Illinois
DecidedMay 22, 2025
Docket3:23-cv-02948
StatusUnknown

This text of French v. Wills (French v. Wills) 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
French v. Wills, (S.D. Ill. 2025).

Opinion

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

MARCELLUS A. FRENCH, SR., ) M21081, ) ) Plaintiff, ) ) vs. ) Case No. 23-cv-2948-DWD ) ANTHONY WILLS, ET. AL, ) ) Defendants. )

MEMORANDUM & ORDER

DUGAN, District Judge:

Plaintiff Marcellus A. French, Sr., an inmate of the Illinois Department of Corrections (IDOC) currently detained at Menard Correctional Center (Menard), brings this civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. (Doc. 12). Specifically, Plaintiff alleges that his rights were violated during two separate disciplinary proceedings, the conditions of confinement in segregation were improper, he has been denied medical care, and his grievances have been mishandled. The Court dismissed Plaintiff’s initial complaint for failure to state a claim, and it allowed him to proceed on a single conditions of confinement claim presented in his amended complaint. Plaintiff now moves for leave to file a second amended complaint, and defendant has responded. For reasons explained in this Order, and in prior reviews of Plaintiff’s pleadings, the Second Amended Complaint (Doc. 63-1) will be rejected because it does not contain any additional claims that are viable. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a)-(b). Any portion of a complaint that

is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations of the pro se complaint are to be liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). THE SECOND AMENDED COMPLAINT

Plaintiff alleges in his Motion for Leave to Amend (Doc. 63) that his proposed second amended complaint (Doc. 63-1) complies with Local Rule 15(a)(1), but his proposed amended complaint does not comply with the rest of Local Rule 15. Notably, his First Amended Complaint was 49 pages long, but his second amended complaint is just 36 pages. Local Rule 15.1(b)(2) requires that amended material must either be

underlined or redlined to demonstrate the differences between pleadings. Plaintiff has not indicated what differs between his first and second amended complaints, and the Court did not engage in a tireless exercise of comparing the pleadings page-by-page to explain the differences in this order. Instead, the Court read the proposed Second Amended Complaint for substance and considered if the allegations in the Second

Amended Complaint presented a valid basis to designate additional claims in this case. It appears in general terms that Plaintiff has adopted the claims designated by this Court in the Order for Service of Process (Doc. 15). Of those claims, the Court allowed just one to proceed (Claim 3), while it dismissed three others. The claims were: Claim 1: Fourteenth Amendment Due Process claim against Defendants Schoenbeck and Jones concerning November 2022 disciplinary ticket;

Claim 2: Fourteenth Amendment Due Process claim against Defendants Schoenbeck and Jones concerning April 2023 disciplinary ticket;

Claim 3: Eighth Amendment conditions of confinement claim concerning segregation placement;

Claim 4: First Amendment retaliation claim against Defendant Wills.

(Doc. 15 at 8). Plaintiff has organized his second amended pleading into three claims, and he has reorganized them so that Claim 1 is the conditions claim and Claims 2 and 3 deal with the disciplinary proceedings. (Doc. 63-1). Despite designating just three claims, it appears that Plaintiff has attempted to shoehorn numerous sub-theories into the claims. For example, he faults defendant Anthony Wills for deliberate indifference to his medical needs for multiple conditions within the scope of claim 1, and in other places throughout the complaint he faults Wills for denying his First Amendment right to access the grievance procedure. In association with the due process claims, he additionally faults defendants for violating his right to equal protection. Having thoroughly reviewed Plaintiff’s two previous pleadings, and having read the 36-page amended complaint in detail, the Court will briefly analyze the claims without recounting the facts at length. This is appropriate because the Court did not detect, and Plaintiff did not clearly highlight via underlining, any facts or assertions that are materially different from previous pleadings. He argues in his motion to amend that he has provided greater detail about things now that he has been able to access his grievance records, but to the extent he talks about problems with the grievance process, or dissatisfaction with Warden Wills’ handling of his grievances, neither of these things

changes the substantive analysis of the Due Process or Eighth Amendment claims nor creates a freestanding First Amendment claim. There is no protected interest in access to or the functionality of the grievance process itself, so Plaintiff’s allegations about Wills violating his First Amendment right relative to the grievance process are insufficient to state a claim. See e.g., Owens v. Hinsley, 635 F.3d 950, 953 (7th Cir. 2011) (the alleged mishandling of grievances by persons who did not otherwise cause or participate in

underlying conduct is insufficient to state a claim). Perhaps Plaintiff is going for an allegation that Wills turned a blind eye to the issues he raised in his grievances, but most of his allegations just generically complain about Wills designating grievances emergency or non-emergency or his signing off without thoroughly investigating. The bare assertion that Wills should be at fault for

designating grievances emergency or non-emergency, or for reaching a certain substantive outcome on grievances, is not enough to support any additional plausible claims against him under the First, Eighth, or Fourteenth Amendments. In the proposed amended pleading, Plaintiff also attempts to reframe his Eighth Amendment deliberate indifference to medical needs claims as claims against Defendant

Wills for his handling of grievances related to these issues. Previously, Plaintiff presented allegations about various medical ailments against two defendants who worked in his cellhouse while he was in segregation from April to September of 2023. The Court dismissed those allegations as too ambiguous because Plaintiff did not explain when or how he sought care from these defendants, he did not clearly explain the severity of the conditions for which he sought care, and he did not explain any specific harm associated

with a delay or denial of care. (Doc. 15 at 9-10). Plaintiff has now reframed just some of his deliberate indifference to a medical needs claims (exposure to waste after the cellhouse was flooded with human waste, lack of exercise related to his gunshot wound, and secondhand smoke exposure) against Wills on the premise Wills received and reviewed grievances about these issues but failed to ensure care was provided. Again, Plaintiff’s allegations lack much detail about his physical state, and they do not clearly

describe harm associated with any delay or denial of care, other than the generic assertion that he still has pain.

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Related

Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Courtney Ealy v. Cameron Watson
109 F.4th 958 (Seventh Circuit, 2024)

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French v. Wills, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-v-wills-ilsd-2025.