Laster v. Blanchette

CourtDistrict Court, C.D. Illinois
DecidedFebruary 11, 2025
Docket2:25-cv-02021
StatusUnknown

This text of Laster v. Blanchette (Laster v. Blanchette) 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
Laster v. Blanchette, (C.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION

JOVARIS LASTER, Plaintiff,

v. Case No. 2:25-cv-02021-JEH

JEROME COMBS DETENTION CENTER, et al., Defendants.

Order

Plaintiff Jovaris Laster, proceeding pro se and detained at the Jerome Combs Detention Center, filed a Complaint under 42 U.S.C. § 1983 alleging violations of his constitutional rights. (Doc. 1). This case is before the Court for a merit review of Plaintiff’s Complaint pursuant to 28 U.S.C. § 1915A. The Court must “screen” Plaintiff’s Complaint and dismiss any legally insufficient claim or the entire action if warranted. § 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 true, 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). Plaintiff files suit against the Jerome Combs Detention Center (“JCDC”) and Jerome Combs Medical Department Staff. When Plaintiff entered the JCDC on July 19, 2024, correctional officer Blanchette moved him to housing unit Flex A, Cell 1. Plaintiff alleges that he told Blanchette he had epilepsy and a medical permit for a bottom bunk, but Blanchette told Plaintiff he had to use the top bunk because another inmate was already assigned the bottom bunk. Plaintiff also alleges he did not receive his morning dose of his seizure medication on July 21, 2024. Plaintiff informed a correctional officer, who said he would call the nurse. Although it was only 10:30 or 11:00 a.m., the nurse allegedly refused to give Plaintiff his medication because it would “overlap with [his] day meds.” Id. at p. 5. Later that day, Plaintiff alleges he had an epileptic seizure, fell off the top bunk onto the floor, and hit the right side of his head. As a detainee, Plaintiff’s claims arise under the Due Process Clause of the Fourteenth Amendment. Miranda v. Cnty. of Lake, 900 F.3d 335, 353-54 (7th Cir. 2018) (detainees entitled to adequate medical care). To establish a Fourteenth Amendment violation, a detainee must show: “(1) there was an objectively serious medical need; (2) the defendant committed a volitional act concerning the [plaintiff’s] medical need; (3) that act was objectively unreasonable under the circumstances in terms of responding to the [plaintiff’s] medical need; and (4) the defendant act[ed] purposefully, knowingly, or perhaps even recklessly with respect to the risk of harm.” Gonzalez v. McHenry Cnty., Illinois, 40 F.4th 824, 828 (7th Cir. 2022) (citation and internal quotation marks omitted). Based on Plaintiff’s allegations, the Court finds that he has stated a plausible Fourteenth Amendment deliberate indifference claim against (1) correctional officer Blanchette for allegedly assigning Plaintiff to the top bunk on July 19, 2024, despite knowing that Plaintiff had epilepsy and a medical permit for a bottom bunk, and (2) the unidentified nurse who allegedly refused to give Plaintiff his morning dose of seizure medication on July 21, 2024. The Clerk is directed to add correctional officer Blanchette and nurse Jane Doe as Defendants. Plaintiff is advised that a Doe Defendant cannot be served, and he is responsible for identifying nurse Jane Doe. Plaintiff did not include allegations against other medical staff members in his Complaint. Therefore, Defendant Jerome Combs Medical Department Staff is dismissed without prejudice. Plaintiff also named the JCDC as a Defendant, but a jail is not a “person” amenable to suit under § 1983. Dye v. Wargo, 253 F.3d 296, 299 (7th Cir. 2001); see also Nava v. Sangamon Cnty. Jail, No. 14-3090, 2014 WL 1320259, at *2 (C.D. Ill. Apr. 2, 2014) (Sangamon County Jail is not a person that may be sued under § 1983). The JCDC is dismissed with prejudice. Finally, Plaintiff filed a Motion to Request Counsel asking the Court to appoint an attorney to represent him. (Doc. 5). “There is no right to court- appointed counsel in federal civil litigation.” Olson v. Morgan, 750 F.3d 708, 711 (7th Cir. 2014). When evaluating a request for counsel, the Court must consider: “(1) has the indigent plaintiff made a reasonable attempt to obtain counsel or been effectively precluded from doing so; and if so, (2) given the difficulty of the case, does the plaintiff appear competent to litigate it himself?” Pruitt v. Mote, 503 F.3d 647, 655 (7th Cir. 2007). Demonstrating a reasonable attempt to obtain counsel “is a mandatory, threshold inquiry that must be determined before moving to the second inquiry.” Eagan v. Dempsey, 987 F.3d 667, 682 (7th Cir. 2021) (citing Davis v. Moroney, 857 F.3d 748, 753 (7th Cir. 2017)). Plaintiff has not demonstrated a reasonable attempt to secure his own lawyer. Therefore, Plaintiff’s motion is denied. If Plaintiff renews his motion, he is directed to attach copies of letters he sent to or received from prospective counsel and list attorneys or law firms he contacted and indicate whether he received a response. IT IS THEREFORE ORDERED: 1) According to the Court's merit review of Plaintiff's Complaint under 28 U.S.C. § 1915A, this case shall proceed on a Fourteenth Amendment deliberate indifference claim against (1) Defendant Blanchette for allegedly assigning Plaintiff to the top bunk on July 19, 2024, despite knowing that Plaintiff had epilepsy and a medical permit for a bottom bunk, and (2) Defendant Jane Doe for allegedly refusing to give Plaintiff his morning dose of seizure medication on July 21, 2024. Additional claims shall not be included in the case above, except in the Court's discretion on motion by a party for good cause shown under Federal Rule of Civil Procedure 15. 2) The Clerk is directed to ADD Blanchette (Correctional Officer) and Jane Doe (Nurse) as Defendants. 3) Plaintiff is advised that an unidentified Doe Defendant cannot be served. As a result, the Sheriff of Kankakee County, Michael Downey, will be named as a Defendant, in his official capacity only, for the sole purpose of assisting Plaintiff in the identification of Defendant Jane Doe. The Clerk is directed to ADD Sheriff Downey as a Defendant. After Defendant Jane Doe has been identified, the Sheriff may move to be dismissed. Plaintiff is placed on notice that it is his responsibility, through initial disclosures and discovery, to identify Defendant Jane Doe. The failure to do so will result in her dismissal without prejudice.

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Related

Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Jeffrey Olson v. Donald Morgan
750 F.3d 708 (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)
Michael Davis v. Donald Moroney
857 F.3d 748 (Seventh Circuit, 2017)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)

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Bluebook (online)
Laster v. Blanchette, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laster-v-blanchette-ilcd-2025.