Lunford v. Zawitowski

CourtDistrict Court, N.D. Indiana
DecidedFebruary 23, 2022
Docket3:22-cv-00078
StatusUnknown

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

Bluebook
Lunford v. Zawitowski, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

QUINCY ISAIAH LUNFORD,

Plaintiff,

v. CAUSE NO. 3:22-CV-78-JD-MGG

ZAWITOWSKI, et al.,

Defendants.

OPINION AND ORDER Quincy Isaiah Lunford, a prisoner proceeding without a lawyer, filed this action under 42 U.S.C. § 1983. (ECF 1.) Under 28 U.S.C. § 1915A, the court must screen the complaint and dismiss it if it is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief against a defendant who is immune from such relief. To proceed beyond the pleading stage, a complaint must contain sufficient factual matter to “state a claim that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the pleaded factual content allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Because Mr. Lunford is proceeding without counsel, the court must give his allegations liberal construction. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Mr. Lunford is a pretrial detainee at the St. Joseph County Jail. He alleges that on November 22, 2021, inmates in his housing unit engaged in a “peaceful protest” in the dayroom because they were upset about not getting the commissary items they had ordered. In response, Warden Olmstead (first name unknown) directed staff to spray the dayroom with chemical spray. After being sprayed, he immediately began to “lock

down” by going in his cell and closing the door. At that point, his face was burning and he was having difficulty breathing. He went to the sink to wash the spray off his face, but discovered that the water had been shut off. He claims an officer told him that this was done at the direction of the Warden and Captain Zawitowksi (first name unknown), the jail’s Assistant Warden. It appears the water remained off for about 25 minutes, during which time he claims to have experienced burning and discomfort due

to the chemical spray. Around midnight that night, Officer Swanigan (first name unknown) began to pass out clean towels, sheets, and clothing, but did not give inmates in Mr. Lunford’s unit any fresh linens. He claims his towels and clothing were contaminated with chemical spray, but he was not given any clean linens for two days, which in his view

was meant to punish the inmates for the incident in the day room. He further claims that on November 22, 2021, and November 23, 2021, his attorney was turned away when trying to visit him because the unit was on lockdown. He was also unable to have contact visits with his mother and sister during this two-day period, even though they had already arranged a visit. He alleges that an unspecified disciplinary charge was

brought against him based on the disturbance in the day room, but he was ultimately found “not guilty.” Because Mr. Lunford was a pretrial detainee when these events occurred, his claims must be analyzed under the Fourteenth Amendment. Miranda v. Cty. of Lake, 900 F.3d 335, 352 (7th Cir. 2018). “Pre-trial detainees cannot enjoy the full range of freedoms of unincarcerated persons.” Tucker v. Randall, 948 F.2d 388, 390–91 (7th Cir. 1991)

(citation omitted). Nevertheless, the Fourteenth Amendment prohibits “punishment” of pretrial detainees. Bell v. Wolfish, 441 U.S. 520, 535 (1979). A pretrial detainee states a valid Fourteenth Amendment claim by alleging that (1) the defendant “acted purposefully, knowingly, or perhaps even recklessly,” and (2) the defendant’s conduct was “objectively unreasonable.” Miranda, 900 F.3d at 353–54. “A jail official’s response to serious conditions of confinement is objectively unreasonable when it is ‘not

rationally related to a legitimate nonpunitive governmental purpose[.]’” Mays v. Emanuele, 853 F. App’x 25, 27 (7th Cir. 2021) (citing Kingsley v. Hendrickson, 576 U.S. 389, 398 (2015)). In determining whether a challenged action is objectively unreasonable, courts must consider the “totality of facts and circumstances.” Mays v. Dart, 974 F.3d 810, 819 (7th Cir. 2020), cert. denied, 142 S. Ct. 69 (2021). “[N]egligent conduct does not

offend the Due Process Clause,” and allegations of negligence, even gross negligence, do not suffice. Miranda, 900 F.3d at 353. To establish an excessive force claim under the Fourteenth Amendment, the plaintiff must allege that “the force purposefully or knowingly used against him was objectively unreasonable.” Kingsley, 576 U.S. 396-97. In determining whether force was

objectively unreasonable, courts consider such factors as the relationship between the need for force and the amount of force that was used, the extent of any injuries the plaintiff suffered, and the severity of the security problem. Id. at 397. Here, Mr. Lunford acknowledges that the inmates in the dayroom were engaging in a “protest.” Although he characterizes it as “peaceful,” [i]nmates cannot be permitted

to decide which orders they will obey, and when they will obey them.” Soto v. Dickey, 744 F.2d 1260, 1267 (7th Cir. 1984). The court also considers that prison officials are to be afforded substantial deference on matters related to safety and security of the facility. Bell, 441 U.S. at 547 (“Prison administrators . . . should be accorded wide-ranging deference in the adoption and execution of policies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional

security.”). Given the scenario Mr. Lunford describes, he does not plausibly allege that prison officials violated the Fourteenth Amendment by using chemical spray to disperse the inmates who were protesting in the dayroom. Nevertheless, the complaint can be read to allege that the disturbance broke up when the chemical spray was employed, but that prison officials continued to punish

the participants by shutting off their water and denying them fresh linens for two days. As a result, Mr. Lunford allegedly suffered burning and discomfort to his face and body. Further factual development may show that prison officials acted reasonably to restore order in the facility, but Mr. Lunford has alleged enough to proceed past the pleading stage against Warden Olmstead, Captain Zawitowski, and Officer Swannigan.

Unreasonable restrictions that impede an inmate’s ability to speak to his attorney can also violate the Constitution. Murphy v. Walker, 51 F.3d 714, 718 (7th Cir. 1995). For instance, “[t]he Sixth Amendment right to counsel would be implicated if plaintiff was not allowed to talk to his lawyer for [an] entire four-day period” following his arrest. Tucker v. Randall, 948 F.2d 388, 390–91 (7th Cir.

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Related

Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Block v. Rutherford
468 U.S. 576 (Supreme Court, 1984)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Michael L. Martin v. Sheriff Richard Tyson
845 F.2d 1451 (Seventh Circuit, 1988)
Richard Murphy v. Richard E. Walker
51 F.3d 714 (Seventh Circuit, 1995)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Edward Tobey v. Brenda Chibucos
890 F.3d 634 (Seventh Circuit, 2018)
Alfredo Miranda v. County of Lake
900 F.3d 335 (Seventh Circuit, 2018)
Louis Wozniak v. Ilesanmi Adesida
932 F.3d 1008 (Seventh Circuit, 2019)
Anthony Mays v. Thomas Dart
974 F.3d 810 (Seventh Circuit, 2020)
Soto v. Dickey
744 F.2d 1260 (Seventh Circuit, 1984)

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Lunford v. Zawitowski, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lunford-v-zawitowski-innd-2022.