Gaddis v. Zanotti

CourtDistrict Court, S.D. Illinois
DecidedOctober 30, 2020
Docket3:19-cv-00781
StatusUnknown

This text of Gaddis v. Zanotti (Gaddis v. Zanotti) 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.

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Gaddis v. Zanotti, (S.D. Ill. 2020).

Opinion

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

DONALD D. GADDIS, ) ) Plaintiff, ) ) vs. ) Case No. 19-cv-781-DWD ) BRANDON ZANOTTI, ) ) Defendant. )

MEMORANDUM & ORDER

DUGAN, District Judge:

On July 19, 2019, Plaintiff Donald D. Gaddis filed suit against Defendant Brandon Zanotti, State’s Attorney for Williamson County, Illinois, alleging that he was being denied his constitutional right to bail and was facing retaliation for exercising his First Amendment rights. Gaddis seeks to certify a class of similarly situated individuals who were denied their right to bail when they were required to submit to a mental health evaluation at their expense without justification. His remaining claims are not brought on behalf of a class. Now before the Court are Defendant’s motion to dismiss for failure to state a claim and for lack of jurisdiction (Doc. 14) and his motion to strike class allegations (Doc. 15). For the reasons delineated below, the Court grants Defendant’s motion to strike and grants in part and denies in part the motion to dismiss.

FACTUAL ALLEGATIONS Beginning in the fall of 2017, Plaintiff Donald D. Gaddis placed numerous signs in his yard and in public places. The signs commented on what he describes as matters of public concern with respect to policies, practices, and decisions of local government officials, including Defendant Brandon Zanotti. Gaddis alleges that, in response to his

signs, he faced a range of unconstitutional conduct by Zanotti and by people under Zanotti’s control, including the bringing of many criminal cases and the filing of several orders of protection against Gaddis. He takes issue with Zanotti handling any criminal or civil actions involving him due to what he describes as a conflict of interest because some of Gaddis’s signs targeted Zanotti personally. Gaddis seeks both money damages and injunctive and declaratory relief.

In Count I, Gaddis alleges that his troubles began on or about June 29, 2018, when he was arrested by officers with the Marion Police Department and was charged with a Class 4 felony and a misdemeanor. He describes the arrest as a false arrest. On July 2, 2018, Gaddis posted bail and was released. As a condition of his release, Gaddis was ordered to submit to and pay for a mental health evaluation, a condition he alleges

Zanotti’s office inappropriately demanded and received without a hearing. On July 18, 2018, a special prosecutor was appointed, and the felony charge was dismissed on August 13, 2018. Gaddis did not participate in the ordered evaluation. On or about November 30, 2018, Gaddis again was arrested on a Class 4 felony by officers with the Johnston City Police Department. Zanotti, or an attorney in his office,

requested bond be set at $50,000, but the judge set bond at $30,000. Gaddis posted bail, and he was again ordered to submit to a mental health evaluation at his expense without being provided with a reason for the examination. Gaddis alleges that an Assistant State’s Attorney requested the condition in retaliation for the signs that were critical of Zanotti and other local officials. On December 10, 2018, a special prosecutor was appointed. Gaddis moved to reconsider the appropriateness of the condition requiring a mental

health evaluation on January 9, 2019, and the state court struck the condition in May 2019. He did not participate in or pay for an evaluation. Gaddis seeks to bring his claim about the constitutionality of the mental health evaluation condition on behalf of a class of similarly situated individuals. He alleges that Zanotti has a pattern and practice of conditioning release upon a mental health evaluation at defendants’ expense without adequate justification. Gaddis further claims that

defendants are without redress because there is no right to appeal their bail requirements. He suggests that the evaluations also infringe upon criminal defendants’ Fifth Amendment rights against self-incrimination. According to Gaddis, a class should be certified to address whether Zanotti infringes on criminal defendants’ rights by including a mental health evaluation as a

condition of release and whether Zanotti should be required to provide a factual basis for the bond condition at a hearing before the condition is imposed. Plaintiff seeks money damages in the amount of attorneys’ fees incurred resisting the mental health evaluation conditions and injunctive relief preventing Defendant from requesting a mental health evaluation unless a number of conditions are met, including a showing of a compelling

state interest before imposing the condition. In Count II, Gaddis alleges that he has faced retaliation in the form of at least 10 different criminal and traffic cases in which Zanotti or members of his office appeared for bail hearings or assisted individuals in filing for orders of protection, even though Zanotti had the above-described conflict of interest. He also alleges that Zanotti’s office refused to assist him in filing for orders of protection against individuals who falsely accused or

harassed him. In addition to money damages, Gaddis seeks an injunction prohibiting Zanotti from filing criminal or civil cases against him and from appearing at initial appearances and bail hearings in criminal cases involving Gaddis. In Count III, Gaddis alleges that he was denied his constitutional right to bail when he was arrested twice on the same misdemeanor warrant. On or about April 17, 2019, Gaddis was arrested and charged with a misdemeanor. He posted bond in the amount of

$150, and he was released. On April 18, 2019, Gaddis was arrested a second time for the same charges in the same case. He had to post a second bond in the amount of $300 to be released. He alleges that Zanotti is responsible for his re-arrest because Zanotti presented the warrant for execution a second time even though Gaddis had already been arrested and released. He claims that Zanotti has a policy and practice of failing to adequately

train, supervise, and control his personnel and encourages the type of misconduct that led to Gaddis’s re-arrest. He seeks money damages, including damages for emotional distress and punitive damages. In Count IV, Gaddis alleges that Zanotti has an ongoing conflict of interest with respect to criminal cases against Gaddis. He asks the Court for a declaratory judgment

stating that Zanotti has a conflict of interest that prohibits him from participating in any manner in the prosecution of Gaddis for any alleged crimes. He also seeks injunctive relief barring Zanotti from participating in any manner in the prosecution of Gaddis in any alleged crimes in the future. MOTION TO STRIKE A motion to strike class allegations is analyzed under Federal Rule of Civil

Procedure 23. As is true with a motion for class certification, the plaintiff bears the burden of showing class certification is appropriate. See Valentine v. WideOpen West Finance, LLC, 288 F.R.D. 407, 414 (N.D.Ill. 2012). To obtain class certification under Rule 23, a plaintiff must satisfy each requirement of Rule 23(a) – numerosity, commonality, typicality, and adequacy of representation – and one subsection of Rule 23(b). See Harper v. Sheriff of Cook

County, 581 F.3d 511, 513 (7th Cir. 2009); Oshana v. Coca-Cola Co., 472 F.3d 506, 513 (7th Cir. 2006). Here, Plaintiff cites both Rule 23(b)(2) and Rule 23(b)(3) as potential bases for certifying a class. Rule 23(b)(2) requires showing that the “party opposing the class has acted or refused to act on grounds that apply generally to the class, so that final injunctive

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