Glenn Cook v. United States of America

CourtDistrict Court, S.D. Illinois
DecidedFebruary 10, 2026
Docket3:24-cv-01152
StatusUnknown

This text of Glenn Cook v. United States of America (Glenn Cook v. United States of America) 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
Glenn Cook v. United States of America, (S.D. Ill. 2026).

Opinion

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

GLENN COOK, ) ) Plaintiff, ) ) v. ) Case No. 24-cv-1152-RJD ) ) UNITED STATES OF AMERICA, ) ) Defendant. )

MEMORANDUM AND ORDER DALY, Magistrate Judge:1 This matter comes before the Court on Plaintiff’s Motion to Appoint Counsel (Doc. 26) and Defendant’s Motion to Dismiss for Lack of Subject Matter Jurisdiction and, Alternatively, to Enter Summary Judgment (Doc. 24), Motion for Leave to File Supplemental Authority (Doc. 27) and Motion to Stay Proceedings (Doc. 28). For the reasons set forth below, Plaintiff’s Motion to Appoint Counsel (Doc. 26) is GRANTED. Defendant’s Motion to Dismiss for Lack of Subject Matter Jurisdiction and, Alternatively, to Enter Summary Judgment (Doc. 24) is DENIED as premature, and Defendant’s Motion for Leave to File Supplemental Authority (Doc. 27) and Motion to Stay Proceedings (Doc. 28) are DENIED as moot.

1 This case has been assigned to the undersigned to conduct all proceedings, including trial and final entry of judgment upon the parties’ full consent pursuant to 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. (Doc. 16). Page 1 of 8 Background

Plaintiff Glenn Cook, an inmate of the Federal Bureau of Prisons (“BOP”) currently detained at the Yazoo City Federal Correctional Institute, brought this action under the Federal Tort Claims Act (“FTCA”) concerning medical issues at the Federal Correctional Institute in Marion, Illinois (“FCI Marion”). (Doc. 1; Doc. 6, p. 1). Plaintiff alleged that beginning in 2021, the FCI Marion Warden failed to ensure proper medical treatment for his detached retina or macular hole, which resulted in blindness in his right eye. (Doc. 1 at 7; Doc. 6, p. 2). He explained it was the Warden’s lack of supervision over other medical staff, including Defendants Dr. Pass, E. Harbison, and Dr. K. Bugg, that ultimately led to blindness in one eye. (Id.). Following preliminary review of the Complaint pursuant to 28 U.S.C. § 1915A, the Court dismissed the individual defendants, and Plaintiff was allowed to proceed on the following claim: FTCA claim against the United States concerning the alleged negligence or medical malpractice for his right eye condition or injuries from January 2021 to present. (Doc. 6, pp. 3-5). Pursuant to the Court’s Scheduling and Discovery Order, as amended, discovery was due

by August 4, 2025, and dispositive motions were due by September 18, 2025. (Docs. 19 & 23). A bench trial was set for April 16, 2026. (Doc. 19). On September 17, 2025, Defendant filed its Motion to Dismiss for Lack of Subject Matter Jurisdiction and, Alternatively, to Enter Summary Judgment (Doc. 24). Defendant argues that Plaintiff lacks standing in fact, because his claim falls under the independent contractor exclusion to the FTCA. (Doc. 24, pp. 21-23). It further argues that summary judgment in its favor should be granted because Plaintiff failed to comply with 735 ILCS § 5/2-622, which requires plaintiffs who bring medical malpractice or negligence claims to submit a certificate of merit. (Id. at 25-29). It further claims that summary judgment is appropriate

Page 2 of 8 because Plaintiff has not offered any evidence to establish proximate cause between his injury and any medical malpractice attributable to the government. (Id.) Plaintiff did not timely respond to Defendant’s motion. Instead, on November 3, 2025, Plaintiff filed a motion seeking the recruitment of counsel, the appointment of a witness expert, and the extension of the deadlines to respond to Defendant’s motion. (Doc. 26). Defendant did not

respond or otherwise object to Plaintiff’s motion. On January 26, 2026, Defendant moved to file a supplemental brief on the recently issued Supreme Court decision Berk v. Choy, No. 24-440, 2026 WL 135974 (U.S. Jan. 20, 2026), and its implication on Defendant’s claim for dismissal for Plaintiff’s failure to comply with 735 ILCS § 5-2/622. (Doc. 27). In light of the upcoming trial setting, Defendant also moved to stay proceedings until the Court’s ruling on Defendant’s dispositive motion. (Doc. 28). Plaintiff’s Motion to Appoint Counsel (Doc. 26) While there is no constitutional or statutory right to counsel for a civil litigant, under Section 1915(e), a district court “may request an attorney to represent any person unable to afford

counsel.” 28 U.S.C. § 1915(e)(1); see also Stroe v. Immigration and Naturalization Services, 256 F.3d 498, 500 (7th Cir. 2001); Zarnes v. Rhodes, 64 F.3d 285, 288 (7th Cir. 1995). When presented with a request to appoint counsel, a court must make the following inquiries: (1) has the indigent plaintiff made a reasonable attempt to obtain counsel or effectively been precluded from doing so, and (2) given the difficulty of the case, does the plaintiff appear competent to litigate it himself. Pruitt v. Mote, 503 F.3d 647, 654-55 (7th Cir. 2007). Plaintiff attached to his motion rejection letters from two law firms, as well as an extensive list of law firms he contacted but never responded to his request for representation. (Doc. 26, pp.

Page 3 of 8 4-6, 11-13). Accordingly, the Court deems the threshold requirement for recruitment of counsel satisfied. Further, the Court finds that at this juncture, the complexity of this case exceeds Plaintiff’s ability to prosecute it on his own. While Plaintiff proceeds on a single FTCA claim, Defendant has raised grounds for dismissal that implicate more intricate legal issues. Plaintiff’s claim involves a

complex medical issue that requires expert medical evidence. In fact, Defendant’s motion for summary judgment relies, in part, on Plaintiff’s failure to provide expert testimony to establish proximate cause for his injury. (Doc. 24, pp. 25-29). Due to his incarceration and limited resources, Plaintiff lacks the ability to engage a medical expert. Plaintiff attaches to his motion a long list of the medical providers he contacted to assess his case, none of whom responded to his request. (Doc. 26, p. 7). Further, Defendant has raised the independent contractor exception to the FTCA. To prevail over that challenge, Plaintiff will need to show that his injury was “caused by the negligent or wrongful act or omission of any employee of the Government,” as opposed to that of an independent contractor. 28 U.S.C. § 1346(b)(1); Gottlieb v. United States, 624 F. Supp. 2d

1011, 1022 (S.D. Ind. 2008). The distinction between an employee and an independent contractor is a fact-sensitive inquiry, and Plaintiff’s transfer to a different facility may further undermine his ability to collect relevant evidence. Further, Plaintiff attributes his injury to the Warden’s lack of supervision over other medical staff, including Dr. Pass, E. Harbison, and Dr. K. Bugg, while Defendant argues that FCI-Marion did not employ any federal employees who were medical specialists concerning the evaluation or treatment of Plaintiff’s eye condition. (Doc. 1 at 7). This again potentially implicates a more intricate proximate cause issue that exceeds Plaintiff’s ability to litigate it as a layperson.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
Glenn Cook v. United States of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glenn-cook-v-united-states-of-america-ilsd-2026.