Karl Haywood v. Wexford Health Sources, Inc., Anthony Wills, Derek Brandt, Latoya Hughes, John Doe Correctional Officers 1-2, Jane Doe Nurse, and John Doe Sergeant

CourtDistrict Court, S.D. Illinois
DecidedApril 30, 2026
Docket3:22-cv-00731
StatusUnknown

This text of Karl Haywood v. Wexford Health Sources, Inc., Anthony Wills, Derek Brandt, Latoya Hughes, John Doe Correctional Officers 1-2, Jane Doe Nurse, and John Doe Sergeant (Karl Haywood v. Wexford Health Sources, Inc., Anthony Wills, Derek Brandt, Latoya Hughes, John Doe Correctional Officers 1-2, Jane Doe Nurse, and John Doe Sergeant) 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
Karl Haywood v. Wexford Health Sources, Inc., Anthony Wills, Derek Brandt, Latoya Hughes, John Doe Correctional Officers 1-2, Jane Doe Nurse, and John Doe Sergeant, (S.D. Ill. 2026).

Opinion

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

KARL HAYWOOD,

Plaintiff,

v. Case No. 3:22-CV-731-NJR

WEXFORD HEALTH SOURCES, INC., ANTHONY WILLS, DEREK BRANDT, LATOYA HUGHES, JOHN DOE CORRECTIONAL OFFICERS 1-2, JANE DOE NURSE, and JOHN DOE SERGEANT,

Defendants.

MEMORANDUM AND ORDER

ROSENSTENGEL, District Judge: Plaintiff Karl Haywood, an inmate of the Illinois Department of Corrections (“IDOC”) who is currently housed at Hill Correctional Center, brings this action under 42 U.S.C. § 1983 alleging his constitutional rights were violated while he was housed at Menard Correctional Center (“Menard”). (Doc. 106). Now pending before the Court is a Motion to Dismiss under Rule 12(b)(6) filed by Defendants Anthony Wills and LaToya Hughes (collectively, “Defendants”). (Doc. 134). For the following reasons, the motion is granted in part and denied in part. BACKGROUND The Court accepts as true the following facts, which are taken from Haywood’s second amended complaint (“SAC,” Doc. 106). During the events at issue in this litigation, Haywood was housed at Menard. On February 17, 2021, multiple inmates in Menard’s East House, where Haywood resided, began throwing trash and debris from their cells. (SAC ¶ 13). Neither Haywood nor his cellmate, Lason Elliott, participated in throwing debris out of their cells. (Id. ¶ 16). After several inmates began to set fire to the debris, officers entered the area to quell the situation and set up cameras to document any further violations. (Id. ¶ 14). The

officers cleaned up some of the trash but left several items of debris in front of a cell neighboring Haywood’s. (Id. ¶ 15). The next day, Correctional Officer Derek Brandt and another officer passed by Haywood’s cell and engaged in an argument with Elliott, Haywood’s cellmate. (Id. ¶¶ 17- 18). At the time, Haywood was asleep in his bunk. (Id. ¶ 19). As Officer Brandt and the other officer were about to leave, Elliott called Brandt a “bitch.” (Id.). Brandt immediately turned around and sprayed pepper spray into the cell indiscriminately, hitting Haywood in the face.

(Id. ¶¶ 19-20). The pepper spray inflamed Haywood’s asthma and temporarily blinded him. (Id. ¶ 20). He screamed for help, but Brandt told him to “shut the fuck up,” leaving him in the cell without medical attention for approximately twenty minutes. (Id.). Instead of arranging for prompt medical care, Officer Brandt assembled a team to conduct a forced cell extraction to transport Haywood to the medical unit. Menard’s medical staff ultimately denied Haywood his prescribed inhaler and other treatment, allegedly in an effort to cover- up the extent of his injuries. (Id. ¶ 26).

After the incident, Officer Brandt prepared a report faulting Haywood. He stated falsely that Haywood was standing at the front of the cell with Elliott, throwing Styrofoam meal trays at him. (Id. ¶¶ 21-22). Officer Brandt also denied that there were any witnesses to the incident, even though another officer was with him at the time. (Id. ¶¶ 23-24). Due to Brandt’s report, Haywood was placed in restrictive housing for five days and faced a disciplinary hearing based on the false report. (Id. ¶ 25). In addition, the cell where he was moved had a strong odor of mildew, and its walls were smeared with blood and feces. (Id. ¶ 27). Menard’s staff did not give him a pillow or sheets, and the mattress smelled like urine. (Id. ¶ 27). The sergeant responsible, designated here as “John Doe,” refused Haywood’s

request for cleaning supplies and ignored his concern that his mental illness would be exacerbated by the conditions in the cell. (Id. ¶¶ 28-29). Haywood filed an internal grievance seeking medical care and an independent investigation of the incident with Brandt. (Id. ¶ 30). His grievance specifically requested that video footage from the cameras in East House be preserved. (Id.). Anthony Wills, who was Menard’s warden at the time, relied on Brandt’s report and denied the grievance. (Id. ¶ 31). Haywood acknowledges that the disciplinary action against him was later expunged because

Elliott accepted full responsibility, but he complains that no action was taken to punish Brandt or preserve the video evidence. (Id. ¶¶ 31, 34). Haywood says Wills’s refusal to take proper action against Brandt left him vulnerable to retaliation. (Id. ¶ 32). He alleges that the entire incident has caused a worsening of his asthma and his mental health. (Id. ¶ 33). Haywood filed this action on April 14, 2022. (Doc. 1). The Court later recruited counsel to represent him pro bono. (Doc. 22). In the second amended complaint, Haywood raises claims against four individuals: Officer Brandt, Warden Wills and IDOC Acting Director

LaToya Hughes, in both their individual and official capacities, and an unnamed IDOC Sergeant, presently designated as “John Doe Sergeant.” In the motion now before the Court, Wills and Hughes seek to dismiss the Haywood’s four claims against them. Haywood alleges that (1) Wills and Hughes, in their official capacities, ratified Officer Brandt’s unlawful conduct in violation of the Eighth and Fourteenth Amendments (Count V); (2) Wills, in his individual capacity only, was deliberately indifferent to his need for medical treatment in violation of the Eighth Amendment (Count VI); (3) Wills and Hughes, in both their official and individual capacities, violated his right to due process by destroying certain video evidence (Count VII); and (4) Wills and Hughes, in both their official and individual

capacities, negligently spoliated video evidence in violation of state law (Count VIII). Haywood seeks, among other things, compensatory and punitive damages and an order directing Wills and Hughes to preserve video evidence, “refrain from continuing to perpetuate the false narrative” of the event, correct his record, and punish Brandt. LEGAL STANDARDS A defendant’s motion to dismiss may be granted in instances where the plaintiff’s complaint fails to “state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6).

For a plaintiff to survive a motion to dismiss, the complaint must contain sufficient factual allegations “to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). To be plausible, an allegation must allow “the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The factual allegations stated in the second amended complaint will be taken as true and interpreted in “the light most favorable” to the plaintiff. Burke v. 401 N. Wabash Venture,

LLC, 714 F.3d 501, 504 (7th Cir. 2013). However, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements” are not entitled to the presumption of truth. Ashcroft, 556 U.S. at 678. This standard does not require “detailed factual allegations.” Bell Atl. Corp., 550 U.S. at 555. Rather, it simply requires that that the plaintiff gives “enough details about the subject-matter of the case to present a story that holds together.” Swanson v. Citibank, N.A., 614 F.3d 400, 404 (7th Cir. 2010). DISCUSSION Wills and Hughes argue that all the claims against them are legally defective and must be dismissed.

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Karl Haywood v. Wexford Health Sources, Inc., Anthony Wills, Derek Brandt, Latoya Hughes, John Doe Correctional Officers 1-2, Jane Doe Nurse, and John Doe Sergeant, Counsel Stack Legal Research, https://law.counselstack.com/opinion/karl-haywood-v-wexford-health-sources-inc-anthony-wills-derek-brandt-ilsd-2026.