JEREMY MCSPARREN v. JOSHUA MCDONALD et al.

CourtDistrict Court, C.D. Illinois
DecidedJune 4, 2026
Docket3:25-cv-03288
StatusUnknown

This text of JEREMY MCSPARREN v. JOSHUA MCDONALD et al. (JEREMY MCSPARREN v. JOSHUA MCDONALD et al.) 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
JEREMY MCSPARREN v. JOSHUA MCDONALD et al., (C.D. Ill. 2026).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION

JEREMY MCSPARREN, ) Plaintiff, ) ) v. ) Case No. 25-3288 ) JOSHUA MCDONALD et al., ) Defendants. )

ORDER COLLEEN R. LAWLESS, United States District Judge: Before the Court for screening is a Complaint (Doc. 1) filed under 42 U.S.C. § 1983 by Plaintiff Jeremy McSparren, an inmate at Graham Correctional Center. Plaintiff also filed Motions for Counsel (Doc. 5). I. Complaint A. 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 a complaint, the court accepts the factual allegations as true and construes them liberally 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). B. Analysis

Under Federal Rule of Civil Procedure 8(a), a complaint need only contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “This requirement is satisfied if the complaint (1) describes the claim in sufficient detail to give the defendant fair notice of what the claim is and the grounds upon which it rests and (2) plausibly suggests that the plaintiff has a right to relief above

a speculative level.” Bravo v. Midland Credit Mgmt., 812 F.3d 599, 601–02 (7th Cir. 2016); see also Charleston v. Bd. of Trs. of the Univ. of Ill. at Chi., 741 F.3d 769, 772 (7th Cir. 2013) (“Instead, a plausible claim must include ‘factual content’ sufficient to allow the court ‘to draw the reasonable inference that the defendant is liable for the misconduct alleged.’”) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). In addition to describing the claim, a

plaintiff must also give “some indication . . . of time and place.” Thomson v. Washington, 362 F.3d 969, 971 (7th Cir. 2004). Plaintiff’s pleading identifies nineteen individuals and entities that Plaintiff generally claims either denied him medical treatment for a litany of medical conditions or responded unfavorably to his grievances. Plaintiff also fails to specify dates when these

various violations occurred. The vague or conclusory manner in which Plaintiff presents his allegations do not state plausible claims against the identified Defendants. Although Plaintiff does not need to provide a lengthy account of the circumstances underlying his allegations, he should provide facts that specify the constitutional

violation, when it occurred, and the Defendant or Defendants personally involved. See Gentry v. Duckworth, 65 F.3d 555, 561 (7th Cir. 1995) (“To recover damages under § 1983, a plaintiff must establish that a defendant was personally responsible for the deprivation of a constitutional right.”). Thus, the Court dismisses Plaintiff’s Complaint (Doc. 1) but grants Plaintiff leave to file an amended pleading. In the interest of efficiency and judicial economy, the Court provides the following guidance.

Plaintiff does not state a § 1983 claim against individuals who merely process or review grievances, absent facts showing their personal involvement. See Owens v. Evans, 878 F.3d 559, 563 (7th Cir. 2017) (“Prison officials who simply processed or reviewed inmate grievances lack personal involvement in the conduct forming the basis of the grievance.”); see also George v. Smith, 507 F.3d 605, 609 (7th Cir. 2007) (“Only persons who

cause or participate in [constitutional] violations are responsible.”). “Section 1983 only permits an individual to sue a ‘person’ who deprives that individual of his or her federally-guaranteed rights under color of state law.” Snyder v. King, 745 F.3d 242, 246 (7th Cir. 2014). Thus, neither the Illinois Department of Corrections nor the Administrative Review Board is considered a person under § 1983. See Fairley v.

Fermaint, 482 F.3d 897, 904 (7th Cir. 2006) (“State agencies are not ‘persons’ under § 1983 . . . .”); see also White v. Knight, 710 F. App’x 260, 262 (7th Cir. 2018) (“[T]he fact that a building is owned by a corporate entity or a government agency does not make the building a suable person under § 1983.”). Supervisors cannot be held liable under a theory of respondeat superior. Jones v.

Chicago, 856 F.2d 985, 992 (7th Cir. 1988); see also Miller v. Harbaugh, 698 F.3d 956, 960 (7th Cir. 2012) (“Because there is no vicarious liability under Section 1983, [supervisory] defendants [can] be liable only if they personally did something that violated [a plaintiff’s] rights.”); Ashcroft v. Iqbal, 556 U.S. 662, 676 (2009) (“Government officials may not be held liable for the unconstitutional conduct of their subordinates under a theory of respondeat superior.”).

Defendant Wexford Health Sources, Incorporated can be held liable under § 1983 if an unconstitutional act is caused by: “(1) an official policy adopted and promulgated by its officers; (2) a governmental practice or custom that, although not officially authorized, is widespread and well settled; or (3) an official with final policy-making authority.” Thomas v. Cook Cty. Sheriff’s Dept., 604 F.3d 293, 303 (7th Cir. 2010); see also

Woodward v. Corr. Med. Servs. of Ill., Inc., 368 F.3d 917, 927-28 (7th Cir. 2004) (stating that the standard for municipal liability in Monell v. N.Y. City Dep’t of Soc. Servs., 436 U.S. 658 (1978), applies to corporations as well).

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Thomas v. Cook County Sheriff's Department
604 F.3d 293 (Seventh Circuit, 2010)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Brian K. Thomson v. Odie Washington
362 F.3d 969 (Seventh Circuit, 2004)
Cheryl Miller v. Dr. Jolene Harbaug
698 F.3d 956 (Seventh Circuit, 2012)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
David Snyder v. J. King etal
745 F.3d 242 (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)
Katiuska Bravo v. Midland Credit Management, Inc
812 F.3d 599 (Seventh Circuit, 2016)
James Owens v. John Evans
878 F.3d 559 (Seventh Circuit, 2017)
Donyall White v. Wendy Knight
710 F. App'x 260 (Seventh Circuit, 2018)

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JEREMY MCSPARREN v. JOSHUA MCDONALD et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeremy-mcsparren-v-joshua-mcdonald-et-al-ilcd-2026.