Howell v. Watkins

District Court, C.D. Illinois·Decided October 10, 2023·No. 1:23-cv-01030·Unknown

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

MICHAEL HOWELL, ) ) Plaintiff, ) ) v. ) 23-1030 ) CHRIS WATKINS, et al. ) ) Defendants. )

SUMMARY JUDGMENT ORDER Plaintiff, proceeding pro se and presently incarcerated at Sheridan Correctional Center, brought the present lawsuit pursuant to 42 U.S.C. § 1983 alleging a Fourteenth Amendment claim for inhumane conditions of confinement arising from his detention at the Peoria County Jail. The matter comes before this Court for ruling on the Defendant’s Motion for Summary Judgment on the issue of exhaustion of administrative remedies. (Doc. 17). The motion is granted. SUMMARY JUDGMENT STANDARD Summary judgment should be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). All facts must be construed in the light most favorable to the non-moving party, and all reasonable inferences must be drawn in his favor. Ogden v. Atterholt, 606 F.3d 355, 358 (7th Cir. 2010). The party moving for summary judgment must show the lack of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). In order to be a “genuine” issue, there must be more than “some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586 (1986). “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). FACTS1 Plaintiff filed this lawsuit on January 30, 2023, alleging that Peoria County Jail (“jail”)

was covered in mold, had bugs crawling out of the sinks, and standing water everywhere. (Doc. 1). The Court found that Plaintiff stated a Fourteenth Amendment inhumane conditions of confinement claim. (Doc. 7). Detainees may file a grievance at the jail if they are complaining “that services are substandard or that a rule, regulation, or officers’ conduct is improper.” UMF 11. Jail rules require an inmate to file a grievance via the kiosk system within five days of the events in question. Id. A detainee who is not satisfied with a jail official’s response may appeal the grievance “by submitting a kiosk grievance” within five days of the response asking the Correctional Superintendent to review the answer. Id. If still not satisfied, the detainee “shall forward his or her complaint to the Illinois Office of Jail and Detention Standards.” Id.

Plaintiff filed a grievance dated January 19, 2023, raising some of the conditions at issue in this lawsuit. (Doc. 21-2 at 4). A jail official’s response dated February 2, 2023, states “answered previously.” Id. The other grievances in the record are not relevant to Plaintiff’s claims. Id. at 1-3.

1 Plaintiff did not respond to Defendant’s motion for summary judgment despite being warned of the consequences for failure to do so. The Court considers the facts asserted in Defendant’s motion as undisputed for purposes of this ruling. Fed. R. Civ. P. 56(e)(2). DISCUSSION Failure to exhaust is an affirmative defense, and, therefore, defendants bear the burden of showing that a detainee failed to exhaust all available remedies. Davis v. Mason, 881 F.3d 982, 985 (7th Cir. 2018). The Prison Litigation Reform Act (PLRA) provides:

No action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.

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