Gerken v. Wills

CourtDistrict Court, S.D. Illinois
DecidedJuly 24, 2025
Docket3:25-cv-00998
StatusUnknown

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

Opinion

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

CHRISTOPHER GERKEN, M12556, ) ) Plaintiff, ) ) vs. ) ) ANTHONY WILLS, ) Case No. 25-cv-998-DWD JOHN DOE, ) MARY WILSON, ) CARRIE MORRIS, ) ERIN NICHOLSON, ) MR. BRAUNING, ) ) Defendants. )

MEMORANDUM & ORDER

DUGAN, District Judge:

Plaintiff Christopher Gerken, an inmate of the Illinois Department of Corrections (IDOC) currently detained at Pontiac Correctional Center, brings this civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights at Menard Correctional Center (Menard). (Doc. 1). Specifically, Plaintiff alleges that he spent over 100 days in the restrictive housing segregation unit where he had zero access to recreation or mental health programming. The Complaint (Doc. 1) is now before the Court for preliminary review pursuant to 28 U.S.C. § 1915A. 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 COMPLAINT

On August 22, 2024, Plaintiff was placed in the restrictive housing unit of Menard’s North 2 cellhouse, where he resided until December 11, 2024, when he was transferred to Pontiac. During his 111 days in this housing unit, Plaintiff alleges that he was not afforded any yard, recreation, or out-of-cell time for even a single hour of a single day. He claims that this total isolation and confinement exacerbated an existing chronic back injury and caused him to suffer pain on a daily basis. He asked Defendants Wills and John Doe about access to recreation or out-of-cell time on a regular basis when they made tours of his gallery, but he got no response. He alleges he also submitted a grievance in November of 2024 about the issue, but his grievance was never processed. Despite the verbal complaints and grievances, he faults Wills and John Doe for never doing anything

to remediate the situation. Plaintiff claims that Wills and John Doe’s conduct violated his Eighth Amendment rights, was discriminatory, and violated his right to Due Process. Additionally, Plaintiff alleges that he notified mental health staff of the lack of recreation and the lack of mental health sessions, which both negatively impacted his mental health. He explains that he has been on the mental health caseload for seven

years, receiving treatment for his depression, anxiety, and PTSD. Defendants Nicholson and Mr. Brauning made weekly rounds, at which time he raised his concerns. They stated they would escalate the concerns up the chain-of-command, but neither they nor Defendants Carrie Morris or Mary Wilson ever did anything about the situation. Plaintiff expressed concern that his mental health was deteriorating, but nothing changed.

Based on the allegations in the Complaint, the Court designates the following counts: Claim 1: Eighth or Fourteenth Amendment claim against Defendants Wills and John Doe for failing to address Plaintiff’s lack of recreation or out-of-cell time from August of 2024 thru December of 2024;

Claim 2: Eighth Amendment claim against Defendants Nicholson, Brauning, Morris, and Wilson for their roles in failing to address the extreme isolation or lack of mental health care from August to December of 2024.

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 claim that is mentioned in the Complaint but not addressed in this Order is considered dismissed without prejudice as inadequately pled under Twombly. See Bell Atl. 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”). DISCUSSION Claim 1 Plaintiff faults Wills and John Doe for violating his Eighth Amendment rights via the conditions of confinement and the impact on his physical health. To establish a conditions of confinement claim, an inmate must establish (1) a deprivation that is, from an objective standpoint, sufficiently serious that it results in the denial of the minimal civilized measure of life’s necessities, and (2) where prison officials are deliberately indifferent to this state of affairs. Gray v. Hardy, 826 F.3d 1000, 1005 (7th Cir. 2016), citing Farmer v. Brennan, 511 U.S. 825, 824 (1994). Conditions may be considered collectively

when analyzing a conditions of confinement claim, and the duration of the allegedly harmful conditions is relevant to the existence of an Eighth Amendment violation. Id. Many conditions standing alone may not be sufficient to give rise to an Eighth Amendment conditions of confinement claim, but they must also be considered collectively. Gillis v. Litscher, 468 F.3d 488, 493 (7th Cir. 2006). “Lack of exercise may rise to a constitutional violation in extreme and prolonged situations where movement is

denied to the point that the inmate's health is threatened.” Antonelli v. Sheahan, 81 F.3d 1422, 1432 (7th Cir. 1996); see also Delaney v. DeTella, 256 F.3d 679, 684 (7th Cir. 2001) (holding that inmate denied meaningful chance to exercise for six months created viable Eighth Amendment claim). Here, Plaintiff alleges that he was denied all forms of recreation or out-of-cell

exercise for 111 days. He claims that during this time he physically deteriorated, particularly due to an existing chronic back injury. He reported his concerns about the lack of recreation both verbally and via a grievance, but Wills and John Doe offered no assistance. At this juncture, these allegations are sufficient to proceed on Claim 1 against Wills and John Doe under the Eighth Amendment.

Plaintiff also claims that Defendants Wills and John Doe violated his right to due process by denying yard or recreation time and discriminated against him by refusing recreation time because his cellhouse was the only one out of the entire prison that did not get any yard or recreation time. (Doc. 1 at 7). Plaintiff’s complaint is insufficient as to any due process claim because he does not provide any factual allegations about the events that led to his placement in restrictive housing. Without any background, the

Court cannot assess the process he was afforded.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McCleskey v. Kemp
481 U.S. 279 (Supreme Court, 1987)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Engquist v. Oregon Department of Agriculture
553 U.S. 591 (Supreme Court, 2008)
Michael C. Antonelli v. Michael F. Sheahan
81 F.3d 1422 (Seventh Circuit, 1996)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Terrance Flynn v. Marion Thatcher
819 F.3d 990 (Seventh Circuit, 2016)
Marcos Gray v. Marcus Hardy
826 F.3d 1000 (Seventh Circuit, 2016)
Taphia Williams v. Thomas Dart
967 F.3d 625 (Seventh Circuit, 2020)
Walker v. Samuels
543 F. App'x 610 (Seventh Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Gerken v. Wills, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gerken-v-wills-ilsd-2025.