Leon Clair v. Anthony B. Jones, Crane, John/Jane Does 3-6

CourtDistrict Court, S.D. Illinois
DecidedOctober 17, 2025
Docket3:25-cv-00364
StatusUnknown

This text of Leon Clair v. Anthony B. Jones, Crane, John/Jane Does 3-6 (Leon Clair v. Anthony B. Jones, Crane, John/Jane Does 3-6) 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
Leon Clair v. Anthony B. Jones, Crane, John/Jane Does 3-6, (S.D. Ill. 2025).

Opinion

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

LEON CLAIR, ) ) Plaintiffs, ) ) vs. ) Case No. 25-cv-364-DWD ) ANTHONY B. JONES, ) CRANE, ) JOHN/JANE DOES 3-6, ) ) Defendants. )

MEMORANDUM AND ORDER

DUGAN, District Judge: This matter is before the Court on the Complaint filed jointly by Leon Clair, Jordan Bailey, and Blake Wilson, all inmates of the Illinois Department of Corrections (IDOC) who resided at Menard Correctional Center (Menard) when this complaint was filed. Specifically, on March 18, 2025, the Court reviewed the jointly filed claims and severed three claims from the original case into the present case that were solely related to Plaintiff Leon Clair. (Doc. 1). Clair has now paid his initial filing fee to proceed, and the Complaint (Doc. 2) is ripe for review on the previously designated claims. The Court is required to screen prisoner complaints and to filter out nonmeritorious claims. 28 U.S.C. § 1915A(a). The Court is required to dismiss any portion of the Complaint that is legally frivolous or malicious, fails to state a claim for relief, or seeks money damages from a defendant who is immune from relief. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations in the pro se Complaint are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Complaint

Plaintiff Clair alleges that on January 24, 2023, John Doe 3, a “transit” lieutenant at Shawnee applied handcuffs in a manner that was too tight and caused extreme pain. (Doc. 2 at 21). Plaintiff claims he complained and cried out in pain during the entire ride, but his handcuffs were not adjusted. He alleges that upon arrival at Menard, he was re- cuffed tightly behind his back to a stool. The handcuffs dug deep into his wrists, almost

immediately caused his entire arms to go numb, and caused bleeding. Plaintiff called out for help and Defendant Jones eventually responded. He explained that his arms, hands, and shoulders were numb and that he needed the handcuffs adjusted, but Jones merely glanced and asked Plaintiff to “be cool.” About ten minutes after Jones left, Jane Doe 4 (a nurse) came for a medical

screening. Plaintiff pled for assistance, tried to show that his wrists were bleeding, and explained he previously had a double-cuff permit, but Jane Doe 4 did not help. Jane Doe 5 (a mental health provider) came about ten minutes after Jane Doe 4 to perform a mental health screening. (Doc. 2 at 22). Plaintiff pled for assistance or for his cuffs to be loosened by Jane Doe 5 offered no help. About 15 minutes later, John Doe 6 (an internal affairs

lieutenant) came to interview Plaintiff. Plaintiff expressed his pain and John Doe 6 noted that he was bleeding, but merely reassured Plaintiff he would not have to wait much longer. Plaintiff remained handcuffed for about an hour after the final interview. (Doc. 2 at 22-23). Plaintiff submitted sick call slips from January 24, 2023, through February 2, 2023, before he was finally seen on February 3, 2023. Plaintiff alleged that John Doe 7, the nurse

responsible for scheduling individuals who submit sick call slips, was deliberately indifferent for delaying his access to care for 10 days. (Doc. 2 at 23). Plaintiff alleges that when he saw a nurse they promised to put him in to see a nurse practitioner for a handcuff permit. However, he faults Defendant Crane (a nurse practitioner) for delaying medical treatment for a year by not providing a double-cuff permit for an entire year. (Doc. 2 at 23).

Based on the allegations in the Complaint the Court designated three claims for severance into this case, which it will now re-number as follows: Claim 1: Eighth Amendment excessive force or cruel and unusual punishment claim against Defendants John Doe 3 (transit officer), Jones, and John Does 4-6 for using restraints in a fashion that caused unnecessary pain and lacerations to Plaintiff Clair’s wrists on January 24, 2023, and/or for failing to provide relief or medical care for the injuries sustained;

Claim 2: Eighth Amendment failure to intervene claim against John Does 3-6 for failing to adjust Plaintiff Clair’s restraints on January 24, 2023, once notified that they were causing extreme pain;

Claim 3: Eighth Amendment deliberate indifference claim against Defendant Crane for delaying or denying Plaintiff Clair access to adequate medical care for wrist injuries or to a proper handcuff permit for a year after his arrival at Menard.

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 claim that is mentioned in the Complaint but not addressed in this Order is considered dismissed without prejudice as inadequately pled under Twombly. See Bell Atl. 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 that is plausible on its face”). Preliminary Dismissals Plaintiff Clair named John/Jane Doe 7 in the factual allegations of the complaint and described them as a nurse who was responsible for processing sick call slips in the days after his January 24, 2023, transfer to Menard when he had cuts on his wrists from the handcuffs. He faults John/Jane Doe 7 for delaying his access to timely care. However,

he has not named John/Jane Doe 7 in the caption of the case, so they are not currently a proper defendant in this action. Federal Rule of Civil Procedure 10 requires that a case caption contain the name of each party. Thus, the allegations against John/Jane Doe 7 were deemed insufficient at the time of severance and John/Jane Doe 7 is not listed as a formal party in this severed case.

Analysis Claims 1 and 2 The Eighth Amendment prohibits cruel and unusual punishment. See e.g., Farmer v. Brennan, 511 U.S. 825, 833-34 (1994). An Eighth Amendment excessive force claim requires an inquiry into “whether force was applied in a good-faith effort to maintain or restore discipline, or [whether it was] applied maliciously and sadistically to cause

harm.” Hudson v. McMillian, 503 U.S. 1, 7 (1992). The “core judicial inquiry” for an excessive force claim is not the severity of the injury, but whether the force used was ‘malicious and sadistic.’ Wilkins v. Gaddy, 559 U.S. 34, 37 (2010). Courts have concluded at initial review, and later in litigation, that it is possible handcuffs applied too tightly can be a form of excessive force or cruel and unusual punishment. See e.g., Tibbs v. City of

Chicago, 469 F.3d 661, 666 (7th Cir. 2006); Gates v. Doctors, 2024 WL 5186647 at * 1 (N.D. Ind. Dec. 19, 2024); Phillips v. Riggs, 2018 WL 1738013 at 2 (S.D. Ill. Apr. 11, 2018). Here, Plaintiff’s initial allegations that his cuffs were applied too tightly, or that staff members failed to render aid when he raised the issue, are sufficient to proceed beyond initial review. Plaintiff must file a notice within 30 days giving as much descriptive information as possible about John/Jane Does 3-6.

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Related

Wilkins v. Gaddy
559 U.S. 34 (Supreme Court, 2010)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ronald Tibbs v. City of Chicago and Mark Kooistra
469 F.3d 661 (Seventh Circuit, 2006)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)

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Bluebook (online)
Leon Clair v. Anthony B. Jones, Crane, John/Jane Does 3-6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leon-clair-v-anthony-b-jones-crane-johnjane-does-3-6-ilsd-2025.