Lovejoy v. Ruhl

CourtDistrict Court, C.D. Illinois
DecidedJuly 20, 2022
Docket3:22-cv-03080
StatusUnknown

This text of Lovejoy v. Ruhl (Lovejoy v. Ruhl) 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
Lovejoy v. Ruhl, (C.D. Ill. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS

LAURENCE LOVEJOY, ) ) Plaintiff, ) v. ) No.: 22-cv-3080-MMM ) BRITTANY GREENE, et al., ) ) Defendants. )

MERIT REVIEW ORDER

Plaintiff, proceeding pro se and incarcerated at Western Illinois Correctional Center (“Western”), files a complaint under 42 U.S.C. § 1983 alleging that Defendants retaliated against him in violation of the First Amendment. The case is before the Court for a merit review pursuant to 28 U.S.C. § 1915A. In reviewing the complaint, the Court accepts the factual allegations as true, liberally construing them in Plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649-51 (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 and internal quotation marks omitted). While the pleading standard does not require “detailed factual allegations,” it requires “more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). FACTS Plaintiff alleges that a tactical team executed a shakedown of cells at Western on June 11, 2021. Plaintiff was sitting at the desk in his cell working on a new lawsuit when Defendant Hill Ruhl, a correctional officer, ordered Plaintiff to stop what he was doing and exit his cell. When Plaintiff asked if his legal materials would be safe, Defendant Ruhl assured Plaintiff that his legal materials would be fine and told him that he would be the officer conducting the shakedown of his cell. Plaintiff alleges that when he returned to his cell after the shakedown, he discovered that his research materials, affidavits, declarations from witnesses, copies of letters sent to attorneys, memos, letters and requests sent to the warden complaining about the conditions of confinement,

and other documents were missing. Plaintiff alleges that Defendant Ruhl confiscated his legal materials in retaliation for filing previous lawsuits. Plaintiff states that he planned to file his lawsuit on June 14, 2021, but due to the disappearance of his legal materials, he was unable to file it. Despite his requests, Plaintiff claims that the legal materials have not been returned. Plaintiff also alleges that Defendant Rob Jeffreys, the Director of the Illinois Department of Corrections (“IDOC”), failed to remedy the alleged constitutional violations described in the grievances he submitted. Plaintiff claims that Defendant Jeffreys “turned a blind eye to it, failed to remedy it, or in some way personally participated.” (Doc. 1 at 5). Plaintiff states that he had nine conversations with Defendant Brittany Greene, the Warden

of Western, about being subjected to unconstitutional conditions of confinement. He claims that she was deliberately indifferent by refusing to resolve his complaints and protect him from dangerous situations. Plaintiff alleges further that Defendant Greene retaliated against him for exercising his First Amendment right to file administrative grievances and that she conspired with Defendants Jeffreys and Ruhl to harm him. ANALYSIS Prisoners have a protected First Amendment right to file lawsuits and grievances. Dobbey v. IDOC, 574 F.3d 443, 446 (7th Cir. 2009). A prisoner may not be disciplined for filing a grievance or lawsuit as “[a]n act taken in retaliation for the exercise of a constitutionally protected right violates the Constitution.” DeWalt v. Carter, 224 F.3d 607, 618 (7th Cir. 2000). To establish First Amendment retaliation, Plaintiff must successfully allege that (1) his speech was constitutionally protected; (2) he has suffered a deprivation likely to deter free speech; and (3) his speech was at least a motivating factor in the Defendant’s action. See Massey v. Johnson, 457 F.3d 711, 716 (7th Cir. 2006). Here, Plaintiff alleges that Defendant Ruhl retaliated against him for

filing prior lawsuits by confiscating his legal materials during the shakedown. As a result, Plaintiff claims he was unable to file the lawsuit he was working on. At this juncture, the Court finds that Plaintiff has stated a plausible First Amendment retaliation claim against Defendant Ruhl. Defendants Jeffreys and Greene Plaintiff claims that Defendant Jeffreys was aware of his complaints based on the grievances he filed, but he failed to remedy the alleged constitutional violations. He also alleges that Defendant Jeffreys “turned a blind eye to it, failed to remedy it, or in some way personally participated.” (Doc. 1 at 5). These conclusory statements do not establish that Defendant Jeffreys was personally involved in any constitutional deprivation, and therefore, he is not liable in his

individual capacity. See Pepper v. Vill. of Oak Park, 430 F.3d 805, 810 (7th Cir. 2005) (citations omitted) (“[T]o be liable under [Section] 1983, an individual defendant must have caused or participated in a constitutional deprivation.”). Plaintiff alleges in a conclusory fashion that Defendant Greene retaliated against him for filing grievances, refused to resolve his complaints, and failed to protect him from dangerous situations. (Doc. 1 at 6). A warden cannot be held liable based solely on her involvement in the grievance process. See Thomas v. Knight, 196 Fed. Appx. 424, 429 (7th Cir. 2006) (explaining that a warden does not incur § 1983 liability just by participating in the grievance process). “If there is ‘no personal involvement by the warden outside the grievance process,’ that is insufficient to state a claim against the warden.” Neely v. Randle, No. 12 C 2231, 2013 WL 3321451, at *3 (N.D. Ill. June 13, 2013) (quoting Gevas v. Mitchell, 492 Fed. Appx. 654, 660 (7th Cir. 2012). Plaintiff also alleges that he had multiple conversations with Defendant Greene, but he provides no additional information about the conversations. See Diaz v. McBride, No. 3:93-CV- 176RM, 1994 WL 750707, at *4 (N.D. Ind. Nov. 30, 1994) (holding that a plaintiff could not

establish personal involvement, and subject a prison official to liability under § 1983, merely by sending the official various letters complaining about the actions or conduct of subordinates). Plaintiff’s allegations are insufficient to demonstrate that Defendant Greene was personally involved in the alleged confiscation of his legal materials. Additionally, Defendants Jeffreys and Greene are not liable merely because of their supervisory positions, as the doctrine of respondeat superior (supervisor liability) does not apply to actions filed under § 1983. See Pacelli v. DeVito, 972 F.2d 871, 877 (7th Cir. 1992). The Court finds that Plaintiff has failed to state a claim against Defendants Jeffreys and Greene in their individual capacities. Defendants Jeffreys and Greene are DISMISSED, without prejudice, for

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Romanelli, Ronald v. Suliene, Dalia
615 F.3d 847 (Seventh Circuit, 2010)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Dobbey v. Illinois Department of Corrections
574 F.3d 443 (Seventh Circuit, 2009)
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)
Thomas, Wayman v. Knight, Stanley
196 F. App'x 424 (Seventh Circuit, 2006)
Massey, Michael v. Johnson, Mable
457 F.3d 711 (Seventh Circuit, 2006)
Gevas v. Mitchell
492 F. App'x 654 (Seventh Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Lovejoy v. Ruhl, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lovejoy-v-ruhl-ilcd-2022.