Howard v. Guyton

CourtDistrict Court, C.D. Illinois
DecidedApril 18, 2023
Docket1:22-cv-01186
StatusUnknown

This text of Howard v. Guyton (Howard v. Guyton) is published on Counsel Stack Legal Research, covering District Court, C.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howard v. Guyton, (C.D. Ill. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS

MICHAEL R. HOWARD, ) ) Plaintiff, ) v. ) Case No. 22-cv-1186-MMM ) RONDA GUYTON, et al., ) ) Defendants. )

MERIT REVIEW ORDER – THIRD AMENDED COMPLAINT Plaintiff, proceeding pro se and detained at the Peoria County Jail (“Jail”), files a Third Amended Complaint under 42 U.S.C. § 1983 alleging inhumane conditions of confinement at the Jail. (Doc. 17). The case is before the Court for a merit review pursuant to 28 U.S.C. § 1915A. In reviewing the complaint, the Court accepts the factual allegations as true, liberally construing them in Plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649-51 (7th Cir. 2013). However, conclusory statements and labels are insufficient. Enough facts must be provided to “state a claim for relief that is plausible on its face.” Alexander v. United States, 721 F.3d 418, 422 (7th Cir. 2013) (citation and internal quotation marks omitted). While the pleading standard does not require “detailed factual allegations,” it requires “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Wilson v. Ryker, 451 F. App'x 588, 589 (7th Cir. 2011) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). ALLEGATIONS Plaintiff brings his Third Amended Complaint against sixty Jail employees. (Doc. 17 at 5- 14). First, Plaintiff alleges that there is black mold on the dayroom walls, toilet, and shower, which causes him to experience breathing problems when he showers. Plaintiff wrote grievances and requested cleaning supplies, but he claims detainees use the same dirty mop head for weeks. Second, Plaintiff alleges the Jail’s kitchen is infested with mice, rats, and cockroaches, and he found a cockroach in his chicken noodles. Plaintiff was given a new tray of food, but he claims the bug was cooked with the entire batch of chicken noodles. Plaintiff also alleges that health department inspections are done in-house, and the Jail bombs for cockroaches while food is being prepared.

Third, Plaintiff alleges that the Jail is allowing sexual abuse and harassment because detainees are permitted to wear only their boxers or briefs, even though the handbook requires detainees to wear jail uniforms. Plaintiff wrote requests and grievances asking the Jail to address the ongoing problems to no avail. Plaintiff states that he has been in segregation since January 17, 2022, due to detainees wearing briefs and/or boxers on a daily basis. Fourth, Plaintiff alleges that laundry does not get passed out on a weekly basis, even though the Jail handbook states that “jail-issued bedding and clothing will be laundered twice weekly. Cleanliness and personal hygiene are important to the health of the inmates.” (Doc. 17 at 4). Fifth, Plaintiff complains that the cells are not inspected properly. Plaintiff states that there

is toothpaste, graffiti, and human feces on the cell walls. Plaintiff alleges that he has cleaned eight cells without proper cleaning supplies. Finally, Plaintiff alleges that the Jail has not had hot water since August 21, 2022. ANALYSIS As a pretrial detainee, Plaintiff’s “conditions-of-confinement claim arises under the Due Process Clause of the Fourteenth Amendment, which is governed by an objective standard.” Kemp v. Fulton Cnty., 27 F.4th 491, 495 (7th Cir. 2022) (citing Hardeman v. Curran, 933 F.3d 816 (7th Cir. 2019)). Under this standard, Plaintiff must plead: “(1) the conditions in question are or were objectively serious…; (2) the defendant acted purposefully, knowingly, or recklessly with respect to the consequences of his actions; and (3) the defendant’s actions were objectively unreasonable– that is ‘not rationally related to a legitimate governmental objective or…excessive in relation to that purpose.’” Hardeman, 933 F.3d at 827 (Sykes, J., concurring) (quoting Kingsley v. Hendrickson, 576 U.S. 389, 397 (2015)). “Objective reasonableness ‘turns on the facts and circumstances of each particular case.’” Kemp, 27 F.4th at 495 (quoting Kingsley, 586 U.S. at 397).

This standard is higher than that required to prove negligence, or even gross negligence and is “akin to reckless disregard.” Miranda v. Cnty. of Lake, 900 F.3d 335, 352 (7th Cir. 2018). Plaintiff lists sixty Defendants in Third Amended Complaint, but he does not identify specifically who he complained to or who he notified about the alleged issues. Plaintiff alleges that he submitted numerous grievances and requests, but this is insufficient to establish liability against Defendants. An individual is liable under § 1983 only if he or she personally participated in or caused the alleged deprivation. Palmer v. Marion Cnty., 327 F.3d 588, 594 (7th Cir. 2003); Glasco v. Prulhiere, 2009 WL 54298, at *1 (S.D. Ind. Jan. 8, 2009) (“Even if [plaintiff] wrote letters to these defendants, this fact alone is insufficient to support recovery from supervisory defendants.”);

Diaz v. McBride, 1994 WL 750707, at *4 (N.D. Ind. Nov. 30, 1994) (holding that a plaintiff could not establish personal involvement, and subject a prison official to liability under § 1983, merely by sending the official various grievances). The Court finds that Plaintiff’s allegations are insufficient to state a claim of inhumane conditions of confinement. Plaintiff also alleges that the Jail is permitting sexual abuse and harassment by allowing detainees to wear their briefs and boxers instead of their jail uniforms. Plaintiff claims that he has been in segregation since January 2022 as a result. These allegations are unrelated to the conditions at the Jail and not are properly joined in one lawsuit. Unrelated claims against the same defendant may be joined in one action, but different defendants can be joined in one action only if the claims against them arise from the same series of transactions or occurrences. Fed. R. Civ. P. 18, 20; Kadamovas v. Stevens, 706 F.3d 843 (7th Cir. 2013) (court “can require the plaintiff ‘to file separate complaints, each confined to one group of injuries and defendants.’”) (quoted cite omitted); Wheeler v. Wexford Health Sources, Inc., 689 F.3d 680, 683 (7th Cir. 2012) (“A litigant cannot throw all of his grievances, against dozens of different parties, into one stewpot. Joinder

that requires the inclusion of extra parties is limited to claims arising from the same transaction or series of related transactions.”); George v. Smith, 507 F.3d 605, 607 (7th Cir. 2007) (“Unrelated claims against different defendants belong in different suits . . .”).

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Curtis J. Celske v. Thomas Edwards
164 F.3d 396 (Seventh Circuit, 1999)
Wheeler v. Wexford Health Sources, Inc.
689 F.3d 680 (Seventh Circuit, 2012)
Jurijus Kadamovas v. Michael Stevens
706 F.3d 843 (Seventh Circuit, 2013)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Tapanga Hardeman v. David Wathen
933 F.3d 816 (Seventh Circuit, 2019)
Gregory Kemp v. Fulton County, Illinois
27 F.4th 491 (Seventh Circuit, 2022)
Wilson v. Ryker
451 F. App'x 588 (Seventh Circuit, 2011)

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Bluebook (online)
Howard v. Guyton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-v-guyton-ilcd-2023.