Henneberg v. Vandalia Officials

CourtDistrict Court, S.D. Illinois
DecidedMarch 3, 2021
Docket3:20-cv-00303
StatusUnknown

This text of Henneberg v. Vandalia Officials (Henneberg v. Vandalia Officials) 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
Henneberg v. Vandalia Officials, (S.D. Ill. 2021).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

DONALD HENNEBERG, #Y40172, ) ) Plaintiff, ) vs. ) Case No. 3:20-cv-00303-GCS ) VANDALIA OFFICIALS, ) ) Defendants. )

MEMORANDUM AND ORDER

SISON, Magistrate Judge: Plaintiff Donald Henneberg was a state prisoner incarcerated at Vandalia Correctional Center (“Vandalia”) in the Illinois Department of Corrections (“IDOC”) at the time he filed this civil rights action pursuant to 42 U.S.C. § 1983. He has since been released from custody. (Doc. 7). He alleges deprivations of his constitutional rights while he was confined at Vandalia, in that he was punished for a disciplinary infraction without being afforded due process. He seeks monetary damages. This case is now before the Court for a preliminary merits review of the Complaint under 28 U.S.C. § 1915A,1 which requires the Court to screen prisoner2 Complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). Any portion of the Complaint

1 The Court has jurisdiction to screen the Complaint in light of Plaintiff’s consent to the full jurisdiction of a magistrate judge and the Illinois Department of Corrections’ limited consent to the exercise of magistrate judge jurisdiction, as set forth in the Memorandum of Understanding between this Court and the Illinois Department of Corrections.

2 Although Plaintiff is no longer incarcerated, the pre-screening requirement of § 1915A, which is part of the Prison Litigation Reform Act (“PLRA”), still applies. The determination of a plaintiff’s status as a prisoner or non-prisoner, and thus the applicability of the PLRA, must be made as of the date the lawsuit is filed. See Kerr v. Puckett, 138 F.3d 321, 323 (7th Cir. 1998). that is legally frivolous, malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. See 28 U.S.C. § 1915A(b). At

this juncture, the factual allegations of the pro se Complaint are to be liberally construed. See Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). THE COMPLAINT On February 11, 2020, an unknown first shift officer (John Doe) wrote him a disciplinary ticket for refusing to go to the morning medication line. (Doc. 1, p. 6). Plaintiff asserts he did not “refuse” to go, but instead did not get in the line because he

was not due to receive any morning medications. After Plaintiff was served with the ticket, he wrote a request for an extension on the hearing date so he could gather his evidence and names of witnesses. He gave that request to the “same officer.” (Doc. 1, p. 6). Two days later, Plaintiff was called to the disciplinary hearing where hearing officers Kristina H. and Chris Weber said they could

not find Plaintiff’s request. The hearing officers refused to grant him any additional time, and they found Plaintiff guilty. Plaintiff indicates that his punishment included a loss of good conduct time. (Doc. 1, p. 4, 7). DISCUSSION Based on the allegations in the Complaint, the Court designates the following

single claim in this pro se action: Count 1: Vandalia officials violated Plaintiff’s due process rights by issuing him a false disciplinary ticket and finding him guilty without allowing him to present evidence or witnesses in his defense. Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard.3

The Court finds that the Complaint, as currently drafted, fails to state a claim and must be dismissed. Section 1983 creates a cause of action based on personal liability and predicated upon fault; thus, “to be liable under [Section] 1983, an individual defendant must have caused or participated in a constitutional deprivation.” Pepper v. Vill. of Oak Park, 430 F.3d 805, 810 (7th Cir. 2005). To state a claim against a defendant, a plaintiff

must describe what each named defendant did, or failed to do, that violated the plaintiff’s constitutional rights. Plaintiffs are required to associate specific defendants with specific claims, so that defendants are put on notice of the claims brought against them and so they can properly answer the Complaint. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555; FED. R. CIV. PROC. 8(a)(2). Furthermore, to be treated as a defendant, the party must

be specified in the case caption. See Myles v. United States, 416 F.3d 551, 551-552 (7th Cir. 2005). Here, Plaintiff lists “Vandalia Officials” as the only defendants in the Complaint. (Doc. 1, p. 1-2). Merely asserting that a group of employees violated Plaintiff’s constitutional rights does not meet the pleading standards of Rule 8 of the Federal Rules

of Civil Procedure, which requires a short, plain statement of the case against each individual defendant. See, e.g., Brooks v. Ross, 578 F.3d 574, 580 (7th Cir. 2009)(finding the

3 See, e.g., Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)(noting that 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.”). phrase “one or more of the Defendants” did not adequately connect specific defendants to illegal acts, and thus failed to plead personal involvement); Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009)(finding that a complaint must describe “more than a sheer possibility that a defendant has acted unlawfully”); Twombly, 550 U.S. at 555 (stating that “[f]actual allegations must be enough to raise a right to relief above the speculative level.”). Plaintiff also fails to mention specifically the group he identifies as “Vandalia Officials” in his statement of claim. (Doc. 1, p. 6). Instead, he describes the conduct of a John Doe Officer and two Hearing Committee Officers (Kristina H. and Chris Weber). It

is permissible to use the “John/Jane Doe” designation to refer to parties whose names are unknown – but to do so, Plaintiff must refer to each Defendant individually in the case caption and throughout the Complaint. Additionally, while Plaintiff includes the names of the hearing officers in his statement of claim, he fails to list those persons as Defendants in the case caption or in his description of the parties. (Doc. 1, p. 1-2). Because the

Complaint does not sufficiently list the Defendants in the case caption and then describes these individuals and their conduct in the Complaint, Count 1 and the Complaint (Doc. 1) will be dismissed without prejudice for failure to state a claim upon which relief may be granted. However, Plaintiff shall be given an opportunity to submit an amended complaint to correct the deficiencies in his pleading.

There is an additional issue that may prevent Plaintiff from pursuing this action.

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