Leal v. Pinkerton

CourtDistrict Court, S.D. Illinois
DecidedApril 24, 2024
Docket3:24-cv-00105
StatusUnknown

This text of Leal v. Pinkerton (Leal v. Pinkerton) 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
Leal v. Pinkerton, (S.D. Ill. 2024).

Opinion

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

JORGE LUIS LEAL,

Plaintiff,

v. Case No. 24-cv-105-NJR

LT. PINKERTON, LT. HAVENS, SGT. CROWSON, SGT. ETHERTON, C/O GIBBS, C/O NORTH, C/O YINGLING, CHIEF HUNTER, C/O CROMPTON, C/O FREEMAN, C/O ALLEN, and C/O CREEK,

Defendants.

MEMORANDUM AND ORDER ROSENSTENGEL, Chief Judge: Plaintiff Jorge Luis Leal, an inmate of the Federal Bureau of Prisons who is currently incarcerated at Federal Correctional Institution—Forrest City, brings this action pursuant to 42 U.S.C. § 1983 for deprivations of his constitutional rights while he was a pretrial detainee at the Williamson County Jail. On January 17, 2024, the claims in this case were severed from Leal’s claims in Leal v. Pinkerton, et al., Case No. 22-cv-1172-SMY, after Leal advised the Court of his desire to proceed with the severed claims (Doc. 1). This case is now before the Court for preliminary review of the Complaint pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). The Complaint

The allegations related to the claims in this severed case are set forth in the merits review Order in Leal v. Pinkerton, et al., Case No. 22-cv-1172-SMY, filed in this case on January 17, 2024 (See Doc. 6, pp. 4-5). The following claims were severed into this case: Count 15: Fourteenth Amendment claim against Crowson, Etherton, Havens, Pinkerton, and Hunter for placing Leal on lockdown with no access to essential services while investigating a PREA claim against him from November 23 until December 8, 2021.

Count 16: Fourteenth Amendment claim against Crompton for denying Leal mental health treatment necessitated by the PREA investigation from November 23 until December 8, 2021.

Count 17: First Amendment claim against North, Yingling, and Freeman for retaliating against Leal for filing a lawsuit by conducting a shakedown of his cell in December 2021 or January 2022.

Count 18: Fourteenth Amendment claim against Hunter, Allen, North, and Havens for denying Leal’s grievance about the shakedown.

Count 19: First and/or Fourteenth Amendment claim against Gibbs for opening two pieces of mail outside of Leal’s presence on January 26, 2022.

Count 20: Fourteenth Amendment claim against Hunter, Creek, Etherton, and North for denying Leal’s related grievance about mail interference that occurred on January 26, 2022.

The parties and the Court will use these designations in all future pleadings and orders, unless otherwise directed by a judicial officer of this Court. 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 the Twombly pleading standard.1

Because Leal was a pretrial detainee at the time his claims arose, his claims implicate the Fourteenth Amendment Due Process Clause. See Kingsley v. Henderson, 576 U.S. 389 (2015); Miranda v. County of Lake, 900 F.3d 335, 350 (7th Cir. 2018). Jail conditions violate the Fourteenth Amendment when they deprive a pretrial detainee of basic human needs, such as food, water, medical care, and safety. Hardeman v. Curran, 933 F.3d 816,

823 (7th Cir. 2019). To state a claim under the Fourteenth Amendment, a pretrial detainee must set forth facts suggesting that each defendant “acted purposefully, knowingly, or perhaps even recklessly” in response to conditions posing an excessive risk to his health or safety and that the defendant’s actions were “objectively unreasonable.” Miranda, 900 F.3d at 352-54. See also Hardeman, 933 F.3d at 823 (“objective inquiry applies to all

Fourteenth Amendment conditions-of-confinement claims brought by pretrial detainees”). Leal fails to state a claim as to Count 15, which alleges that he was denied access to “essential services” while on investigative lockdown. His allegations fail to describe the conditions that he faced while on lockdown. He also fails to describe what essential

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”). services he was deprived of during the lockdown. Without more, Leal fails to state a claim.

As to Count 16, Leal states a claim against Correctional Officer (“C/O”) Crompton for failing to schedule Leal for mental health care. Leal alleges that during his lockdown, his mental health deteriorated, and he expressed suicidal thoughts and concerns to Crompton. He also requested to be seen by mental health staff, but Crompton failed to take action to ensure Leal saw mental health staff for his mental condition. At this stage, Leal adequately alleges that Compton acted knowingly and unreasonably in failing to

obtain care for Leal. Leal’s claim in Count 17 falls under the First Amendment. “First Amendment retaliation cases require the [plaintiff] to show that the speech or activity was constitutionally protected, a deprivation occurred to deter the protected speech or activity, and the speech or activity was at least a motivating factor in the decision to take

retaliatory action.” Manuel v. Nalley, 966 F.3d 678, 680 (7th Cir. 2020). “The ‘motivating factor’ amounts to a causal link between the activity and the unlawful retaliation.” Id. (citation omitted). Leal alleges that after taking steps to file a lawsuit against officials at the jail, C/O North, C/O Freeman, and C/O Yingling conducted a shakedown of his cell that lasted longer than the average shakedown and resulted in his legal materials being

strewn about his cell. At this stage, the allegations state a First Amendment retaliation claim. Leal fails, however, to state a claim in Count 19. “Although prison officials may open a prisoner’s legal mail in his presence, Wolff v. McDonnell, 418 U.S. 539, 577, 94 S.Ct. 2963, 41 L.Ed.2d 935 (1974), repeated instances of a prisoner’s legal mail being opened outside of his presence are actionable.” Greeno v. Litscher, 13 F. App’x 370, 375-76 (7th Cir.

2001) (citing Antonelli v. Sheahan, 81 F.3d 1422, 1431-32 (7th Cir. 1996)). Legal mail is afforded greater protections because it could interfere with a detainee’s right of access to the courts. Kaufman v. McCaughtry, 419 F.3d 678, 685-86 (7th Cir. 2005).

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Related

Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
Michael C. Antonelli v. Michael F. Sheahan
81 F.3d 1422 (Seventh Circuit, 1996)
James J. Kaufman v. Gary R. McCaughtry
419 F.3d 678 (Seventh Circuit, 2005)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Tapanga Hardeman v. David Wathen
933 F.3d 816 (Seventh Circuit, 2019)
Elijah Manuel v. Nick Nalley
966 F.3d 678 (Seventh Circuit, 2020)
Greeno v. Litscher
13 F. App'x 370 (Seventh Circuit, 2001)

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Leal v. Pinkerton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leal-v-pinkerton-ilsd-2024.