Jones v. Granite City Police Department

District Court, S.D. Illinois·Decided October 28, 2022·No. 3:22-cv-01401·Unknown

Opinion

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

GARRETT DOUGLAS JONES, #83695, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-01401-JPG ) GRANITE CITY POLICE DEPT., ) DETECTIVE ROZELL, and ) DETECTIVE BEISHERS, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Garrett Douglas Jones, a pretrial detainee at Madison County Jail, brings this action pro se pursuant to 42 U.S.C. § 1983. Plaintiff claims that Granite City Police Detectives Rozell and Beishers inflicted serious injuries and withheld medical treatment until Plaintiff confessed to swallowing drugs on or around May 9, 2022. (Doc. 1, pp. 1-14). Plaintiff seeks money damages from the defendants. (Id.). The Complaint is subject to preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner Complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). The factual allegations in a pro se complaint are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Complaint Plaintiff sets forth the following allegations in the Complaint (Doc. 1, pp. 1-14): On or around May 9, 2022, Plaintiff was taken to Granite City Police Department for questioning in connection with an undisclosed matter. (Id. at 5, 12). At some point, Detectives Rozell and Beishers walked Plaintiff outside of the police station, and he ran from them. (Id.). The two detectives caught him while he was climbing a fence. (Id.). They punched him in the ribs and head until he fell from the fence. (Id.). Other staff members joined them until it “seemed like the

entire day shift” took part in the beating. (Id. at 9). Plaintiff sustained a concussion, broken ribs, lacerations on his thigh, puncture wounds on his stomach, and a “split” testicle. (Id. at 5, 12). Plaintiff was refused medical treatment until he confessed to swallowing drugs. (Id.). In fact, Detective Rozell told Plaintiff that he “would make this worse” until he confessed. (Id.). When Plaintiff finally admitted to the crime, he was taken to the hospital for treatment of his injuries. (Id.). Some injuries were documented and treated, and others were not. (Id.). However, the toxicology report confirms no presence of drugs in his system. (Id.). Plaintiff now brings claims against Granite City Police Department, Detective Rozell, and Detective Beishers for police brutality, denial of medical treatment, a coerced confession, and denial of equal protection of the law. (Id.).

Preliminary Dismissal Granite City Police Department is named as a defendant, but no claims survive screening against the police department. This entity is not a “person” subject to suit under 42 U.S.C. § 1983. The police department likely represents Plaintiff’s attempt to hold the municipality liable for his injuries. See Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 690, 694 (1978). However, municipal liability under § 1983 arises from the execution of a government policy or custom that causes a constitutional injury, and the allegations point to no policy or custom that caused a constitutional injury to occur here. Accordingly, Granite City Police Department shall be dismissed with prejudice from this action. Discussion Based on the allegations, the Court now recognizes the following enumerated counts in the pro se civil rights Complaint: Count 1: Detectives Rozell and Beishers used excessive force against Plaintiff on or around May 9, 2022.

Count 2: Detectives Rozell and Beishers denied Plaintiff adequate medical treatment for the injuries they inflicted on or around May 9, 2022.

Count 3: Detectives Rozell and Beishers coerced Plaintiff to confess to ingestion of drugs when he ingested none on or around May 9, 2022.

Count 4: Detectives Rozell and Beishers denied Plaintiff equal protection of the law on or around May 9, 2022.

Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under Twombly.1 Count 1

Different standards apply to excessive force claims brought by arrestees, pretrial detainees, and sentenced prisoners. Kingsley v. Hendrickson, 576 U.S. 389, 400 (2015). Because Plaintiff explicitly alleges that he was a pretrial detainee at the time he ran from the two detectives, this claim is analyzed under the standard applicable to a detainee. With that said, the Court would also allow this claim to proceed past screening under the Fourth Amendment standard applicable to arrestees and the Eighth Amendment standard applicable to convicted persons. Pretrial detainees cannot be punished at all. Kingsley, 576 U.S. at 400 (citations omitted). A pretrial detainee bringing an excessive force claim “must show only that the force purposely or knowingly used against him was objectively unreasonable.” Id. No showing regarding the defendant’s state of mind is required. Id. The allegations in the Complaint articulate a Fourteenth

1 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face”). Amendment claim of excessive force against both defendants for their conduct on or around May 9, 2022. See, e.g., Maus v. Baker, 641 F. App’x 596, 599 (7th Cir. 2016) (allowing excessive force claim brought by pretrial detainee to proceed against jail officials who choked and pushed him). Accordingly, Count 1 shall proceed against Detectives Rozell and Beishers.

Count 2

Count 2 is also governed by different standards that depend on the plaintiff’s status as an arrestee, detainee, or prisoner at the time his claim arose. Because Plaintiff identifies himself as a detainee, the Court will apply the Fourteenth Amendment due process standard to the claim at screening. However, the allegations articulate a claim against both defendants, regardless of his status and the applicable standard. A two-part inquiry governs a pretrial detainee’s claim for inadequate medical care. McCann v. Ogle Cty., Illinois, 909 F.3d 881, 886 (7th Cir. 2018); Miranda v. County of Lake, 900 F.3d 335, 353 (7th Cir. 2018). The first part of the inquiry examines whether the “defendants acted purposefully, knowingly, or perhaps even recklessly when they considered the consequences of their handling of [plaintiff’s] case.” McCann, 909 F.3d at 886 (citing Miranda, 900 F.3d at 353). The second part of this inquiry asks whether the defendant’s conduct was objectively reasonable based on the totality of circumstances faced by the defendant. Id.

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