Lewis, Sr. v. Sheriff

CourtDistrict Court, S.D. Illinois
DecidedFebruary 11, 2022
Docket3:20-cv-00514
StatusUnknown

This text of Lewis, Sr. v. Sheriff (Lewis, Sr. v. Sheriff) 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
Lewis, Sr. v. Sheriff, (S.D. Ill. 2022).

Opinion

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

ANDRE G. LEWIS, Sr., ) ) Plaintiff, ) ) vs. ) Case No. 20-cv-00514-JPG ) LT. WHITING, ) SGT. ROBERTS, ) and CPT. SCOTT, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: This matter is before the Court for a decision on a Motion to Dismiss for Failure to State a Claim Pursuant to Federal Rule of Civil Procedure 12(b)(6) (“Rule (12)(b)(6)”) filed by Defendants Lieutenant Whiting, Sergeant Roberts, and Captain Scott. (Doc. 37). For the reasons set forth below, the motion is GRANTED. Background Plaintiff Andre Lewis brings this action pursuant to 42 U.S.C. § 1983 to challenge three disciplinary tickets that resulted in his punishment with segregation at Jefferson County Jail in 2020. In the First Amended Complaint, Plaintiff claims he was deprived of a protected liberty interest without due process of law when he was punished with 57 days of segregation without receiving proper notice or a fair hearing in connection with the three tickets. (Doc. 26). Following screening of this matter under 28 U.S.C. § 1915A, Plaintiff was allowed to proceed with his Fourteenth Amendment claims against Whiting for the second ticket issued April 18, 2020 (Count 2) and against Roberts and Scott for the third ticket issued May 7, 2020 (Count 3). (See Docs. 27-28). When screening the claims under the Fourteenth Amendment, the Court explained that it was required to consider (1) whether there was a protected liberty interest at stake that necessitated due process protections in the first place, and, if so, (2) whether each disciplinary hearing was conducted in accordance with procedural due process requirements. Zinermon v. Burch, 494 U.S. 113, 125 (1990). Different standards apply to due process claims brought by pretrial detainees and

convicted persons arising from punishment with segregation. Prison officials have significant latitude to punish prisoners for their misconduct. Hardaway v. Meyerhoff, 734 F.3d 740 (7th Cir. 2013) (citing Marion v. Columbia Corr. Inst., 559 F.3d 693, 697 (7th Cir. 2009)). When presented with a prisoner’s claim for the deprivation of a protected liberty interest, the Court looks to “the combined import of the duration of the segregative confinement and the conditions endured.” Id. (citing Marion, 559 F.3d at 697 (emphasis in original)). A prisoner’s liberty interest in avoiding segregation is limited. Id. Therefore, if the duration of segregation is short, it may not be necessary to engage in further fact- finding about the conditions faced by the inmate before determining that no protected liberty

interest is at stake. See, e.g., Sandin v. Conner, 515 U.S. 472, 484 (1995); Marion, 559 F.3d at 698 (citing Townsend v. Fuchs, 522 F.3d 765, 766 (7th Cir. 2008) (59 days in segregation); Holly v. Woolfolk, 415 F.3d 678, 679 (7th Cir. 2005) (2 days in segregation); Hoskins v. Lenear, 395 F.3d 372, 374-75 (7th Cir. 2005) (2 months in segregation, demotion to C-grade, and recommendation for transfer); Thomas v. Ramos, 130 F.3d 754 (7th Cir. 1997) (70 days in segregation)). For longer periods of segregation, additional fact-finding into the conditions is generally required. This same analysis does not apply to a pretrial detainee. A person held in pretrial confinement cannot be punished at all for the crime he is suspected of committing because a person is considered innocent until there is a judicial determination of guilt. See Bell v. Wolfish, 441 U.S. 520, 535 (1979). The government may nevertheless take reasonable measures to effectuate pretrial detention, such as those steps required to maintain safety and security at the facility. See Rapier v. Harris, 172 F.3d 999, 1003 (7th Cir. 1999) (citations omitted). As long as those steps are “reasonably related” to the orderly management of the facility, they are not considered punishment

for the crime the detainee is charged with committing. Id. In its screening order, the Court noted that Plaintiff appeared to be a pretrial detainee when his claims arose, triggering “application of the standard described in Rapier for all three disciplinary tickets.” (Doc. 27). He was thus entitled to due process protections before being punished. (Id.). Plaintiff alleged that he was denied the opportunity to be heard, to call witnesses, or to receive a statement of the reasons he was found guilty, among other things. (Id.). On this basis, the Court allowed Counts 2 and 3 to proceed. (Id.). Rule 12(b)(6) Motion to Dismiss In lieu of an Answer, Defendants filed a motion to dismiss both claims based on application

of the standard that governs claims brought by convicted prisoners. (Doc. 37). Defendants argue that Plaintiff was not a pretrial detainee when his claims arose at Jefferson County Jail. Public records reveal that he was a convicted prisoner. They provided documentation of Plaintiff’s criminal case in Indiana that immediately preceded his detention at Jefferson County Jail. According to those records, Plaintiff entered into a plea agreement that resulted in his conviction and subsequent commitment to the custody of the Indiana Department of Corrections in February 2020, just before he was transferred to Jefferson County Jail and received the three disciplinary tickets at issue. (Id.). Plaintiff’s status as a convicted person requires the Court to consider the duration of segregation and conditions faced there, when determining whether a protected liberty interest was at stake. Hardaway, 734 F.3d 740 (citing Marion, 559 F.3d at 697). In light of the short duration of his punishment in segregation, which was no more than 57 days under any construction of the First Amended Complaint, and the lack of harsh conditions described there, Defendants ask the Court to find that no protected liberty interest was at stake and no due process protections required

in connection with the disciplinary tickets. (Doc. 37). Response For his part, Plaintiff disputes his status as a convicted prisoner during the relevant time period. (Doc. 39). Plaintiff maintains that his plea agreement was violated by his transfer to Jefferson County Jail, so he challenged it. (Id.). He also faced other pending charges while at the Jail. (Id.). Plaintiff argues that he should be treated as a pretrial detainee during the relevant time period for both of these reasons. (Id.). According to Plaintiff, application of the standard described in Rapier saves both claims at this stage, so he seeks denial of the pending motion to dismiss. (Id.). Legal Standard

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Related

Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Robert Hoskins v. Connie Lenear
395 F.3d 372 (Seventh Circuit, 2005)
Christopher Holly v. D. Woolfolk
415 F.3d 678 (Seventh Circuit, 2005)
George McReynolds v. Merrill Lynch
694 F.3d 873 (Seventh Circuit, 2012)
Townsend v. Fuchs
522 F.3d 765 (Seventh Circuit, 2008)
Marion v. Columbia Correctional Institution
559 F.3d 693 (Seventh Circuit, 2009)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)
Maurice Hardaway v. Brett Meyerhoff
734 F.3d 740 (Seventh Circuit, 2013)
Gibson v. City of Chicago
910 F.2d 1510 (Seventh Circuit, 1990)

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Lewis, Sr. v. Sheriff, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lewis-sr-v-sheriff-ilsd-2022.