Logan v. Ramirez

CourtDistrict Court, N.D. Illinois
DecidedFebruary 22, 2022
Docket1:21-cv-00131
StatusUnknown

This text of Logan v. Ramirez (Logan v. Ramirez) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Logan v. Ramirez, (N.D. Ill. 2022).

Opinion

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

Davon Logan (#2019-0907022), ) ) Plaintiff, ) ) Case No. 21 C 0131 v. ) ) Hon. Sharon Johnson Coleman Ramirez, et al., ) ) Defendants. )

ORDER

Defendants’ motion to dismiss [24] is denied. Defendants are directed to answer the amended complaint by March 14, 2022. The Clerk is directed to correct Defendant Berthiaume’s name on the docket from the incorrectly spelled “Botheriaum.”

STATEMENT

Plaintiff Davon Logan, formerly a detainee at the Cook County Jail, brings this pro se civil rights action under 42 U.S.C. § 1983. By order of June 8, 2021, the Court allowed Plaintiff to proceed with a claim that Correctional Officer Berthiaume used excessive force by tightening his leg shackles during a transport to the point that it caused injury, while Officer Ramirez failed to intervene in that use of force. Now before the Court is Defendants’ motion to dismiss, to which Plaintiff has responded.

Defendants argue that Plaintiff failed to state a claim for either excessive use of force or freedom from unreasonable restraints. They also contend that Plaintiff failed to allege facts indicating that Officer Ramirez failed to intervene in the alleged constitutional violation.

The Court begins by observing that the Court’s screening order pursuant to 28 U.S.C. § 1915A employed the same standard that applies to Rule 12(b) motions to dismiss. Cesal v. Moats, 851 F.3d 714, 720 (7th Cir. 2017). Further, the Court is obligated to liberally construe pro se complaints, “holding them to a less stringent standard than pleadings drafted by lawyers.” Id.

A motion under Rule 12(b)(6) challenges the sufficiency of the complaint. See Hallinan v. Fraternal Order of Police of Chi. Lodge No. 7, 570 F.3d 811, 820 (7th Cir. 2009). Under Rule 8(a)(2), a complaint must include “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The short and plain statement under Rule 8(a)(2) must “give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citation omitted). Under federal notice pleading standards, a plaintiff’s “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Id. Put differently, a “complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). “In reviewing the sufficiency of a complaint under the plausibility standard, [courts] accept the well-pleaded facts in the complaint as true.” Alam v. Miller Brewing Co., 709 F.3d 662, 665–66 (7th Cir. 2013).

Evaluated under this liberal pleading standard, the Court sees no reason to revisit its screening order allowing these claims to proceed.

Plaintiff’s claims stem from an incident that occurred on July 30, 2020, as Plaintiff and another inmate were being transported back to the jail from Stroger Hospital. (See Pl.’s Am. Compl., Dkt. No. 10, at 5.) The correctional officers transporting them, Berthiaume and Ramirez, put the inmates in the squad car and then inadvertently locked themselves out of the vehicle, with 40 minutes to an hour passing before they could get back inside. (Id.) Plaintiff and the other inmate apparently commented about how it was “funny” that the officers could not get back in the vehicle. (Id. at pgs. 4-5.) Shortly thereafter, when the officers were able to get back into the vehicle, Plaintiff complained about having to use the bathroom. (Id. at pg. 4.) Officer Berthiaume told Plaintiff he could wait until they got back to the jail, and Plaintiff remarked that they already would have gotten back if the officers had not locked themselves out of the vehicle. (Id.) Officer Berthiaume then asked Plaintiff if his leg shackles were too tight, and when Plaintiff replied that they were not, tightened them. (Id. at pg. 4.)

Plaintiff contends that he told Officer Berthiaume that the shackles were too tight, but the officer laughed at him in response and Officer Ramirez, who was driving, pulled away. (Id.) On the way back to the jail, Plaintiff “kept asking” for the shackles to be loosened, but they were not. (Id.) With Plaintiff arrived back at Cermak Hospital, another officer told Plaintiff there was blood in his socks and removed the shackles. (Id.) Plaintiff states that he noticed that the shackles were “cutting deep in my skin.” (Id.) Plaintiff describes these as “deep wound[s],” which were bandaged by a nurse. (Id.)

Defendants argue, first, that it is unclear whether Plaintiff is proceeding on a claim of excessive use of force or a claim of freedom from unreasonable restraints. They cite Davis v. Wessel, 792 F.3d 793, 799–800 (7th Cir. 2015), which drew a distinction between a claim of excessive force and one for “freedom from unreasonable restraints,” as recognized in Youngberg v. Romero, 457 U.S. 307, 321 (1982). The Court observes that the excessive force label applies when a plaintiff is seeking to impose liability for “physically abusive government conduct,” Graham v. Connor, 490 U.S. 386, 394 (1989), which is what Plaintiff seeks to do here. But regardless of the precise label placed on Plaintiff’s claim, the Seventh Circuit has held that the objective reasonableness standard set forth in Kingsley v. Hendrickson, 576 U.S. 389, 396–97 (2015), an excessive force case, applies to all Fourteenth Amendment conditions-of-confinement claims brought by pretrial detainees. Hardeman v. Curran, 933 F.3d 816, 823 (7th Cir. 2019). This requires a showing that the action or condition at issue amounted to punishment because it was not rationally related to a legitimate governmental purpose or was excessive in relation to that purpose. Kingsley, 576 U.S. at 398. The plaintiff also must show that the defendant acted with a purposeful, knowing, or perhaps reckless state of mind with respect to his actions toward the plaintiff. Id. at 395–96. Defendants argue that there was a valid penological reason for Plaintiff to be shackled while being transported from the hospital to the jail. Defendants further contend that the amended complaint contains “no factual allegations that the shackling of Plaintiff was done for punitive reasons.” (See Defs.’ Mot. to Dismiss, Dkt. No. 24, at pg. 5.) The amended complaint, however, gives rise to a reasonable inference that Officer Berthiaume tightened the shackles not for legitimate security reasons, but because he was irritated over Plaintiff needling him about the officers having locked themselves out of the vehicle.

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Related

Wilkins v. Gaddy
559 U.S. 34 (Supreme Court, 2010)
Youngberg v. Romeo Ex Rel. Romeo
457 U.S. 307 (Supreme Court, 1982)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Syed M. Alam v. Miller Brewing Comp
709 F.3d 662 (Seventh Circuit, 2013)
Stainback v. Dixon
569 F.3d 767 (Seventh Circuit, 2009)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Earl Davis v. Seth Wessel
792 F.3d 793 (Seventh Circuit, 2015)
Joseph Wilborn v. David Ealey
881 F.3d 998 (Seventh Circuit, 2018)
Tapanga Hardeman v. David Wathen
933 F.3d 816 (Seventh Circuit, 2019)
Cesal v. Moats
851 F.3d 714 (Seventh Circuit, 2017)

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Logan v. Ramirez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/logan-v-ramirez-ilnd-2022.