Huddleston v. Doe

CourtDistrict Court, S.D. Illinois
DecidedSeptember 19, 2025
Docket3:23-cv-01222
StatusUnknown

This text of Huddleston v. Doe (Huddleston v. Doe) 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
Huddleston v. Doe, (S.D. Ill. 2025).

Opinion

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

JEFFREY D. HUDDLESTON, ) ) Plaintiff, ) ) vs. ) Case No. 3:23-CV-1222-MAB ) SHANE TASKY and CONNIE ) HALLIDAY, ) ) Defendants. )

MEMORANDUM AND ORDER

BEATTY, Magistrate Judge: Presently before the Court is a Motion for Judgment on the Pleadings filed by Defendants Shane Tasky and Connie Halliday (Doc. 60; see also Doc. 61). For the reasons set forth below, Defendants’ Motion for Judgment on the Pleadings is GRANTED (Doc. 60). BACKGROUND Plaintiff Jeffrey Huddleston filed this suit pursuant to 42 U.S.C. § 1983 for alleged violations of his constitutional rights that occurred while he was incarcerated at Big Muddy River Correctional Center (“Big Muddy”) (see Doc. 1; see also Doc. 21). Specifically, Plaintiff’s Complaint alleges that he was to be released on Mandatory Supervised Release on March 1, 2019 (Doc. 1 at p. 6; Doc. 21 at p. 2). However, Defendants denied all of Plaintiff’s proposed host sites for improper reasons (Doc. 21 at p. 2). As a result, Plaintiff was held in IDOC custody for an additional fifteen months beyond his Mandatory Supervised Release date, until he was finally released on June 22, 2020 (Id.). Plaintiff filed his Complaint on April 13, 2023 (Doc. 1). The Court screened the Complaint pursuant to 28 U.S.C. § 1915A and permitted Plaintiff to proceed on one

Eighth Amendment cruel and unusual punishment claim against Defendants John Doe Field Services Supervisor and Jane Doe Clinical Services Supervisor (Doc. 21). Thereafter, Shane Tasky was substituted for the John Doe Defendant and Connie Halliday was substituted for the Jane Doe Defendant (Doc. 47). After receiving Defendants’ Answer (Doc. 57), the Court entered an Initial Scheduling Order that set a deadline of March 10, 2025, for Defendants to file dispositive motions based upon Plaintiff’s failure to exhaust

his administrative remedies (see Doc. 59). On January 27, 2025, Defendants filed the instant Motion for Judgment on the Pleadings (Doc. 60) and Memorandum in Support (Doc. 61). Plaintiff then filed a Response in Opposition on February 24, 2025 (Doc. 64). Defendants did not file a reply in support. Meanwhile, in light of Defendants’ pending Motion for Judgment on the

Pleadings, Defendants moved to stay the deadline to file exhaustion-based dispositive motions (Doc. 65). The Court granted Defendants’ request and stayed the exhaustion- based dispositive motion deadline (Doc. 66). LEGAL STANDARD A party can move for judgment on the pleadings under Federal Rule of Civil

Procedure 12(c) “after the pleadings are closed—but early enough not to delay trial.” FED. R. CIV. P. 12(c). A Rule 12(c) motion for judgment on the pleadings is governed by the same standard as a Rule 12(b)(6) motion to dismiss for failure to state a claim. Federated Mut. Ins. Co. v. Coyle Mech. Supply Inc., 983 F.3d 307, 312 (7th Cir. 2020) (“The only difference between a motion for judgment on the pleadings and a motion to dismiss is timing; the standard is the same.”). Therefore, dismissal is appropriate “when the factual

allegations in the complaint, accepted as true, do not state a facially plausible claim for relief.” Hyson USA, Inc. v. Hyson 2U, Ltd., 821 F.3d 935, 939 (7th Cir. 2016). Regarding affirmative defenses such as the statute of limitations, a plaintiff does not need to anticipate and attempt to allege facts in the complaint negating the affirmative defense. Id. See also Milchtein v. Milwaukee Cnty., 42 F.4th 814, 822 (7th Cir. 2022) (“A complaint need not anticipate affirmative defenses like the statute of limitations and will

not be dismissed just because it does not confirm its own timeliness.”). But when a complaint alleges facts that unambiguously establish the tardiness of the complaint, then dismissal under Rule 12(c) is appropriate. See generally Brownmark Films, LLC v. Comedy Partners, 682 F.3d 687, 690 (7th Cir. 2012); Mohamed v. WestCare Illinois, Inc., 786 Fed. App’x 60, 61 (7th Cir. 2019) (“A district court may enter judgment on the pleadings if the

pleadings show that the statute of limitations blocks the plaintiff’s claims.”); Amin Ijbara Equity Corp. v. Vill. of Oak Lawn, 860 F.3d 489, 492 (7th Cir. 2017) (approving of granting motion to dismiss based on statute of limitations “when the complaint alleges facts sufficient to establish that the suit is indeed tardy.”). The statute of limitations for Plaintiff’s § 1983 claim is two years. Woods v. Illinois

Dep’t of Child. & Fam. Servs., 710 F.3d 762, 768 (7th Cir. 2013) (“[T]he limitations period applicable to all § 1983 claims brought in Illinois is two years.”); see also Johnson v. Rivera, 272 F.3d 519, 521 (7th Cir. 2001) (explaining that federal courts adopt the forum state’s statute of limitations for personal injury claims, which is two years in Illinois). “Moreover, because ‘the chronological length of the limitation period is interrelated with provisions regarding tolling, revival, and questions of application,’ federal courts must

‘also borrow[ ] the state’s tolling rules—including any equitable tolling doctrines.’” Johnson, 272 F.3d at 521 (quoting Smith v. City of Chicago Heights, 951 F.2d 834, 839-40 (7th Cir. 1992)). Accordingly, “a federal court relying on the Illinois statute of limitations in a § 1983 case must toll the limitations period while a prisoner completes the administrative grievance process.” Id. at 522. However, “the accrual date of a § 1983 cause of action is a question of federal law that is not resolved by reference to state law.” Wallace v. Kato, 549

U.S. 384, 388 (2007) (emphasis in original). Thus, under federal law, it is “the standard rule that [accrual occurs] when the plaintiff has a complete and present cause of action, that is, when the plaintiff can file suit and obtain relief.” Id. (internal quotation marks and citations omitted). ANALYSIS

Defendants contend that they are entitled to judgment on the pleadings because Plaintiff’s pleadings demonstrate that he did not file this action within the two-year statute of limitations (Doc. 61 at p. 3). Defendants aver that even when viewing the facts and allegations in the light most favorable to Plaintiff, his cause of action accrued no later than the date of his release on June 22, 2020 (Id. at pp. 3-4). Therefore, because Plaintiff

did not file his Complaint until April 13, 2023, over two years and nine months later, his claim is barred by the statute of limitations (Id.). In response, Plaintiff contends that: (1) he filed numerous grievances during the fifteen-month period he was allegedly wrongfully held at Big Muddy; and (2) he suffers from a legal disability due to Defendants’ allegedly tortious actions, such that the doctrine of equitable tolling should apply (Doc. 64).

Pursuant to federal law, Plaintiff’s Eighth Amendment cruel and unusual punishment claim accrued on the last incidence of the alleged violation. Turley v. Rednour, 729 F.3d 645, 651 (7th Cir. 2013) (“For continuing Eighth Amendment violations, the two- year period starts to run (that is, the cause of action accrues) from the date of the last incidence of that violation, not the first.”).

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Huddleston v. Doe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/huddleston-v-doe-ilsd-2025.