Hinman v. Pulaski County Detention Center

District Court, S.D. Illinois·Decided November 28, 2023·No. 3:23-cv-02610·Unknown

Opinion

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

JARED W. HINMAN, #Y53702, ) ) Plaintiff, ) ) vs. ) Case No. 23-cv-02610-JPG ) OFFICER PETINO, ) OFFICER MIX, ) OFFICER PERRY, ) PULASKI COUNTY SHERIFF’S ) OFFICE, ) PULASKI COUNTY, ) LISA CASPER, ) JORDAN EDWARDS, ) UNKNOWN CELLMATE, and ) UNKNOWN LIEUTENANT, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Now before the Court for preliminary review is Plaintiff Jared Hinman’s First Amended Complaint filed October 11, 2023. (Doc. 11). Plaintiff is a former detainee at Pulaski County Detention Center (“Jail”), and he brings this civil rights action pursuant to 42 U.S.C. § 1983 for constitutional deprivations stemming from his attack by other inmates at the Jail. He seeks unspecified “legal action” and money damages against the defendants. Id. The First Amended Complaint is subject to screening under 28 U.S.C. § 1915A, which requires the Court to filter out claims that are legally frivolous or malicious, fail to state a claim for relief, or request money damages from an immune defendant. 28 U.S.C. § 1915A. At this stage, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). First Amended Complaint Plaintiff sets forth the following allegations in the First Amended Complaint (Doc. 11, p. 6): On July 22, 2023, Officers Mix and Petino placed Plaintiff in a locked shower cage and removed his restraints. An Unknown Lieutenant1 spoke with Inmate Jordan Edwards and his Unknown Cellmate before Officer Mix told them to “have fun” with Plaintiff. For an hour, Inmate

Edwards and the Unknown Cellmate threw feces and sprayed urine at Plaintiff through open meal slots. The Unknown Lieutenant observed the entire incident from the tower/bubble but took no steps to intervene and stop the attack. Id. During an investigation into the incident by “ISP,” Plaintiff provided the investigators with the specific cell number of a witness whose name was unknown at the time but later identified as Inmate Smith. In the meantime, Officer Perry identified this person as Inmate Simms, and State’s Attorney Lisa Casper refused to press charges against anyone after the inmate’s interview with ISP. Id. Preliminary Dismissals

Plaintiff sets forth no factual allegations against the following named defendants: Pulaski County Sheriff’s Office and Pulaski County. Naming a defendant without describing that defendant’s involvement in a constitutional deprivation is insufficient to state a claim. See e.g., Black v. Lane, 22 F.3d 1395, 1401 n. 8 (7th Cir. 1994) (a claim against a defendant is insufficient if the defendant is named, but there are no factual allegations describing that defendant’s personal involvement). Any claim against the Pulaski County Sheriff’s Office or Pulaski County is dismissed without prejudice.

1 Plaintiff identifies this individual as an unknown female lieutenant who has a tattoo of a Roman legion helmet on her forearm. Id. at 6. Discussion The Court designates the following count in the pro se First Amended Complaint: Count 1: Eighth or Fourteenth Amendment claim2 against Defendants for instigating an inmate attack on Plaintiff or failing to protect him from said attack on or around July 22, 2023.

Any claim in the First Amended Complaint that is not addressed herein should be considered dismissed without prejudice as inadequately pled under Twombly.3 The applicable legal standard for this claim hinges on Plaintiff’s status as a pretrial detainee or a prisoner when his claim arose on July 22, 2023. A pretrial detainee’s failure-to-protect claim is assessed under the Fourteenth Amendment, whereas a prisoner’s claim is governed by the Eighth Amendment. See e.g., Thomas v. Dart, 39 F.4th 835, 841 (7th Cir. 2022) (assessing a failure to protect claim by a pretrial detainee under the Fourteenth Amendment); Miranda v. County of Lake, 900 F.3d 335, 350-54 (7th Cir. 2018) (discussing the different legal standards applied to claims by convicted individuals versus pretrial detainees). Plaintiff’s allegations support a claim against Officer Mix, Officer Petino, and Unknown Lieutenant under both standards. All three individuals were involved in instigating the inmate attack or failing to intervene and stop the attack on Plaintiff. Count 1 shall proceed against Mix, Petino, and Unknown Lieutenant. Section 1983 does not extend to disputes involving private citizens, like Inmate Edwards or the Unknown Cellmate. Barnes v. City of Centralia, Ill., 943 F.3d 826, 831 (7th Cir. 2019) (citations omitted). Section 1983 authorizes claims against persons acting under color of state law at the time they violate the plaintiff’s rights. 42 U.S.C. § 1983. Because neither of these

2 The applicable legal standard for this claim depends on Plaintiff’s status as a pretrial detainee or a convicted prisoner, and he did not disclose this information in the First Amended Complaint. 3 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). individuals was acting under color of state law within the meaning of § 1983, Count 1 shall be dismissed without prejudice against them.4 Count 1 shall also be dismissed against Officer Perry for naming the wrong person for an ISP interview. Plaintiff does not allege that the defendant’s conduct was knowing or intentional. The allegations thus describe negligence, at most, in identifying “Inmate Smith” incorrectly as

“Inmate Simms.” (Doc. 11, p. 6). However, negligence does not support a claim under the Eighth or Fourteenth Amendment. Count 1 shall also be dismissed without prejudice against State’s Attorney Lisa Casper. This defendant allegedly failed to press charges against anyone after the wrong inmate (i.e., Inmate Simms) was interviewed during the ISP investigation into Plaintiff’s attack. The Supreme Court has held that “in initiating a prosecution and in presenting the State’s case, the prosecutor is immune from a civil suit for damages.” Imbler v. Pachtman, 424 U.S. 409, 431 (1976). The allegations support no claim against the prosecuting attorney here. Identification of Unknown Defendant

Plaintiff will be allowed to proceed with Count 1 against Defendant Unknown Lieutenant, identified as a female with a tattoo of a Roman legion helmet on her forearm. This defendant must be identified with particularity before service of the First Amended Complaint can be made on her, and Plaintiff will have the opportunity to engage in limited discovery to ascertain her identity. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 832 (7th Cir. 2009). Pulaski County Detention Center’s Jail Administrator shall be added as a defendant, in an official capacity only, and assist in identifying the unknown defendant by name.

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Hinman v. Pulaski County Detention Center, (S.D. Ill. 2023).

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Related

Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Shirlena Barnes v. City of Centralia
943 F.3d 826 (Seventh Circuit, 2019)
Marvin Thomas v. Thomas Dart
39 F.4th 835 (Seventh Circuit, 2022)