Hablutzel v. Illinois

CourtDistrict Court, S.D. Illinois
DecidedDecember 7, 2023
Docket3:23-cv-03375
StatusUnknown

This text of Hablutzel v. Illinois (Hablutzel v. Illinois) 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
Hablutzel v. Illinois, (S.D. Ill. 2023).

Opinion

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

SCOTT M. HABLUTZEL, #Y46216, ) ) Plaintiff, ) ) vs. ) Case No. 23-cv-03375-JPG ) FAYETTE COUNTY ILLINOIS, ) FAYETTE COUNTY, ILLINOIS ) SHERIFF’S DEPARTMENT, ) SHERIFF RONNIE STEVENS, ) DUSTIN CADE, ) BLAIN REDMAN, ) BROC RICH, and ) POLICE DEPT. VANDALIA, IL, ) ) Defendants. )

MEMORANDUM AND ORDER

GILBERT, District Judge:

Plaintiff Scott M. Hablutzel, an inmate in the Illinois Department of Corrections and currently incarcerated at Illinois River Correctional Center, brings this civil rights action pro se pursuant to 42 U.S.C. § 1983 for intentional infliction of emotional distress caused by events preceding his state prosecution for unlawful possession of a firearm and for constitutional deprivations stemming from the denial of mental health treatment at Fayette County Jail. He seeks monetary relief.1 (Doc. 1). The Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A,

1 This is one of four complaints Plaintiff filed on October 13, 2023. See also Hablutzel v. Fayette County, Illinois, et al., Case No. 23-cv-03370-NJR; Hablutzel v. Fayette County, Illinois, Case No. 23-cv-03371- DWD; and Hablutzel v. Fayette County Illinois, et al., Case No. 23-cv-03372-JPG. All four complaints concern events occurring between March 19-24, 2021, in the days leading up to Hablutzel’s state prosecution. The complaints in two cases, i.e., Case No. 23-cv-03370-NJR and Case No. 23-cv-03371- DWD, are virtually identical to one another. The third complaint, i.e., Case No. 23-cv-03372, addresses claims for malicious deprivation of his property. which requires the Court to screen prisoner complaints and filter out claims that are legally frivolous or malicious, fail to state a claim upon which relief may be granted, or ask for money damages from a defendant who by law is immune from such relief. 28 U.S.C. § 1915A(a)-(b). The factual allegations of the pro se Complaint are liberally construed at this stage. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009).

The Complaint In the Complaint, Plaintiff alleges that the defendants caused the intentional infliction of emotional distress when they engaged in misconduct that resulted in his conviction for being a felon in possession of a firearm in Case No. 2021-CF-252. (Doc. 1). Sheriff Stevens contacted his girlfriend and told her that Plaintiff was cheating on her on March 24, 2021, when he was really just using another woman’s garage to restore a vehicle. Unbeknownst to Plaintiff, the garage also contained a gun. Plaintiff was arrested and charged with the unlawful possession of a firearm. Sheriff Stevens, Officer Cade, Officer Redman, and Officer Rich allegedly failed to preserve body camera footage showing that the firearm was actually staged. Plaintiff maintains that the

defendants’ misconduct led to his conviction and sentence for unlawful possession of a firearm following his trial on July 18, 2023. He asserts violations of numerous state laws. Id. at 2. While confined in Fayette County Jail awaiting sentencing, Plaintiff suffered a mental health crisis. He became so distressed that he “clench[ed] his teeth in anger [un]til blood r[an] from [his] mouth.” Id. He had vivid and persistent dreams of committing grisly murders. Plaintiff begged for mental health treatment, but Fayette County Jail did not prioritize mental health. This denial of necessary treatment violated his federal constitutional rights. Id. at 4. Discussion Based on the allegations, the Court designates the following claims in the pro se Complaint: Count 1: Illinois state law claim for intentional infliction of emotional distress against Sheriff Stevens for contacting Plaintiff’s girlfriend to say he was cheating on March 24, 2021.

Count 2: Illinois state law claim for intentional infliction of emotional distress against Sheriff Stevens, Officer Cade, Officer Redman, and Officer Rich for failing to preserve exculpatory evidence for use in Case No. 2021-CF-252.

Count 3: Eighth or Fourteenth Amendment claim against Fayette County Jail for failing to provide Plaintiff with mental health treatment for severe emotional distress.

Any other claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.2 Preliminary Dismissals Plaintiff identifies the following defendants in the Complaint but makes no allegations against them: Fayette County, Illinois; Fayette County Sheriff’s Department; and Vandalia Police Department. If a plaintiff fails to include the name of a defendant in his statement of claim or make any allegations against them, that defendant cannot be said to have notice of which claims, if any, are directed against the party. FED. R. CIV. P. 8(a)(2). In other words, merely invoking the name of a potential defendant is not enough to state a claim. Collins v. Kibort, 143 F.3d 331, 334 (7th Cir. 1998). Accordingly, all three defendants shall be dismissed without prejudice. Counts 1 and 2 Plaintiff brings two separate claims for intentional infliction of emotional distress caused by the defendants’ violations of state law leading up to his arrest. Count 1 arises from allegations of misconduct by Sheriff Stevens, who contacted Plaintiff’s girlfriend and told her Plaintiff was

2 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 to relief that is plausible on its face”). unfaithful. Count 2 arises from allegations of misconduct by Sheriff Stevens, Officer Cade, Officer Redman, and Officer Rich for failing to preserve exculpatory evidence. Both claims arise from various violations of Illinois law. Violations of state law do not give rise to liability against a state actor under § 1983. J.H. ex rel. Higgin v. Johnson, 346 F.3d 788, 793 (7th Cir. 2003) (citing Windle v. City of Marion, Ind.,

321 F.3d 658, 662-63 (7th Cir. 2003); White v. Olig, 56 F.3d 817, 820 (7th Cir. 1995) (“It is therefore a truism, reiterated many times by this court, that mere allegations of state law infractions are insufficient to support a Section 1983 claim.”)). It is only when a state official’s conduct violates federal statutory or constitutional standards that § 1983 liability may be imposed. Plaintiff identifies no deprivations of his federal rights stemming from these facts, so neither claim can proceed under § 1983. Even if federal rights violations were alleged, Plaintiff’s claims for money damages may not be pursued under § 1983, if the success of the claims necessarily implies the invalidity of his criminal conviction or sentence. See Heck v. Humphrey, 512 U.S. 477, 486-87 (1994). On the

present record, the Court lacks sufficient information to determine whether these claims, or any portion of them, are Heck-barred.

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Related

Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Anthony N. Smith v. Knox County Jail
666 F.3d 1037 (Seventh Circuit, 2012)
Windle v. City Of Marion
321 F.3d 658 (Seventh Circuit, 2003)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Powell v. Cook County Jail
814 F. Supp. 757 (N.D. Illinois, 1993)
J.H. Ex Rel. Higgin v. Johnson
346 F.3d 788 (Seventh Circuit, 2003)

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Hablutzel v. Illinois, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hablutzel-v-illinois-ilsd-2023.