Jacobs v. Lovett

CourtDistrict Court, C.D. Illinois
DecidedJune 20, 2025
Docket1:24-cv-01111
StatusUnknown

This text of Jacobs v. Lovett (Jacobs v. Lovett) 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
Jacobs v. Lovett, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

JESSE DUANE JACOBS, ) Plaintiff, ) ) v. ) Case No. 24-1111 ) LOVETT et al., ) Defendants. )

ORDER COLLEEN R. LAWLESS, United States District Judge: Before the Court for screening is a Motion for Leave to File an Amended Complaint (Doc. 14) filed by Plaintiff Jesse Duane Jacobs, an inmate at Federal Correctional Institution (“FCI”) Pekin. I. Screening Standard The Court must “screen” Plaintiff’s complaint and dismiss any legally insufficient claim or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. In reviewing the complaint, the court accepts the factual allegations as accurate, liberally construing them in the plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (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 omitted). II. Factual Allegations Plaintiff alleges violations at FCI Pekin against Corrections Officer Lovett, Lieutenant Doe, and the Bureau of Prisons (”BOP”).

Plaintiff’s twenty-five-page amended pleading recounts a December 2021 search of his cell, in which nine photos depicting female nudity were confiscated. The plaintiff was subsequently escorted to the special housing unit (“SHU”) pending a threat assessment. Before entering the SHU, Plaintiff was handcuffed, which required him to relinquish custody of a digital audio (“MP3”) player, headphones, and a coffee cup

Plaintiff possessed. After SHU processing, Plaintiff received his headphones but not his MP3 player. During his time in the SHU, Plaintiff states that the lights remained on in his cell at night, which affected his sleep. Plaintiff acknowledges that after he submitted an administrative remedy request, the lights were turned off at night. Plaintiff also states

that he was initially denied his “nightly meds,” but this was resolved after speaking to psychology several times. (Pl. Amend. Compl., Doc. 14-1 at 5.) Plaintiff recalls being interviewed after he “wrote what … happened with a male [corrections officer] threatening to rape” him. (Id.) Plaintiff identified Defendant Lovett as the offending officer. Plaintiff was later interviewed about his Prison Rape Elimination

Act (“PREA”) report. The investigating officer recommended that Plaintiff submit an administrative remedy request about the incident, which Plaintiff accomplished. Plaintiff received an unauthorized property rule violation for possessing the nine photos. After spending ninety days in the SHU, Plaintiff was returned to his cell, noting that Defendant Lovett was his housing officer. Plaintiff asserts that he avoided contact with Lovett on the days he worked. Upon his return, Plaintiff was told that Lovett

directed a corrections officer to allow inmates in Plaintiff’s cell to take property. Plaintiff submitted an administrative remedy request regarding this issue and opted to file a property claim after being interviewed. In August 2022, Defendant Lovett “tore [Plaintiff] cell apart.” (Id. at 9.) Plaintiff called for a Lieutenant, who instructed Plaintiff to clean up the mess. The Lieutenant said he would talk to Plaintiff about Plaintiff’s property, but Plaintiff never saw the Lieutenant

again. Plaintiff states that another inmate found pictures in the trash that Plaintiff identified as his property. After Plaintiff submitted an administrative remedy request that was not responded to, he filed a grievance. During an interview on his grievance, Defendant Doe threatened to delete the phone contact lists of some unsavory people and then let them know that Plaintiff was at fault if Plaintiff persisted with his grievance.

Plaintiff acquiesced to Doe’s demands. Two days later, Plaintiff’s phone contact list had been deleted without elaboration. III. Analysis Plaintiff’s complaint proceeds under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, which holds that a victim can seek damages in federal court for

constitutional violations committed by federal officers. 403 U.S. 388, 389 (1971); see also Hernandez v. Mesa, 137 S. Ct. 2003, 2006 (2017) (“Bivens … recognized for the first time an implied right of action for damages against federal officers alleged to have violated a citizen’s constitutional rights.”) (internal quotation marks omitted). However, in Ziglar v. Abbasi, the Supreme Court explained that it applied Bivens in only three implied causes of action: (1) Fourth Amendment unreasonable searches and

seizures, (2) Fifth Amendment due process gender discrimination, and (3) Eighth Amendment deliberate indifference to medical needs. 582 U.S. 120, 131 (2017) (citing Bivens, 403 U.S. at 397, Davis v. Passman, 442 U.S. 228 (1979); Carlson v. Green, 446 U.S. 14 (1980)). The Supreme Court has since “made clear that expanding the Bivens remedy is now a ‘disfavored’ judicial activity[,]” which the Supreme Court has refused to extend for over three decades. Ziglar, 582 U.S. at 135 (collecting cases where the Supreme Court

has declined to extend Bivens to any new context or category of federal defendants). Specifically, the Supreme Court held that because Bivens created a judicial remedy for damages against federal employees instead of a legislated remedy such as 42 U.S.C. § 1983, a federal court should not expand Bivens unless exceptional circumstances exist. Id. at 137.

Plaintiff’s allegations regarding the search of his cell and the confiscation of property by Defendant Lovett are not cognizable under the Fourth Amendment as permitted under Bivens. “[T]he Fourth Amendment proscription against unreasonable searches does not apply within the confines of the prison cell.” Hudson v. Palmer, 468 U.S. 517, 526 (1984); see also Hanrahan v. Lane, 747 F.2d 1137, 1139 (7th Cir. 1984) (“The Supreme

Court’s opinion [in Hudson] precludes Fourth Amendment challenges to prison cell searches taken for any reason, whether or not reasonable.”). Consistent with the Supreme Court’s guidance, the Court declines to conclude that exceptional circumstances exist to expand Bivens to consider Plaintiff’s claims for compensatory and punitive damages under either the due process clause of the Fourteenth Amendment or the First Amendment proscription against retaliation.

Plaintiff also does not state under the PREA, which does not establish a private cause of action. See Ross v. Gossett, 2016 WL 335991, at *4 (S.D. Ill. Jan. 28, 2016 (The PREA “does not create a private cause of action” but instead “establishes finding of facts, sets forth statistics, recites research, adopts standards, and provides for grant money”) (collecting cases); see also Kreig v. Steele, 599 F.App’x 231, 232 (5th Cir.

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Related

United States v. Orleans
425 U.S. 807 (Supreme Court, 1976)
Davis v. Passman
442 U.S. 228 (Supreme Court, 1979)
Carlson v. Green
446 U.S. 14 (Supreme Court, 1980)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Correctional Services Corp. v. Malesko
534 U.S. 61 (Supreme Court, 2001)
Ali v. Federal Bureau of Prisons
552 U.S. 214 (Supreme Court, 2008)
Michael Hanrahan v. Michael P. Lane
747 F.2d 1137 (Seventh Circuit, 1984)
Ronald Glade v. United States
692 F.3d 718 (Seventh Circuit, 2012)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Jackson v. Kotter
541 F.3d 688 (Seventh Circuit, 2008)
Kendale L. Adams v. City of Indianapolis
742 F.3d 720 (Seventh Circuit, 2014)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Hernandez v. Mesa
582 U.S. 548 (Supreme Court, 2017)

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