McDougal v. Penn

CourtDistrict Court, E.D. Wisconsin
DecidedAugust 28, 2020
Docket2:18-cv-01218
StatusUnknown

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

Bluebook
McDougal v. Penn, (E.D. Wis. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

FREDDIE JAMES McDOUGAL, JR.,

Plaintiff,

v. Case No. 18-cv-1218

JANINE MONTOYA, et al.,

Defendants.

ORDER

Plaintiff Freddie James McDougal, Jr. filed a lawsuit against various officials at the Milwaukee County Jail based on allegations that he was given food to which he is allergic and then did not receive proper medical treatment. He has moved to amend his complaint and filed several motions relating to discovery, along with a motion for summary judgment and a motion for default judgment. I will address each motion in turn. 1. Motions to Amend Complaint McDougal filed two motions to amend his complaint. (Docket # 44, 53.) The first motion did not comply with Civil Local Rule 15(a), which requires a party moving to amend their complaint to include a proposed amended complaint with their motion. That motion contains a request to extend deadlines, too, which I will address below. But I will deny the portion of McDougal’s motion that asks to amend his complaint for failure to comply with the Local Rules. McDougal filed another motion to amend his complaint and included the required proposed amended complaint. (Docket # 53.) According to the motion, McDougal received more information in discovery about “times, dates and other people who were [present].” (Id. at 1.) It also seems there may have been some delays in receiving discovery due to issues with mail delivery. (Id. at 1–2.) The defendants oppose the motion, arguing that the date to amend had passed over a month before McDougal filed his motion and that McDougal had

the discovery for nearly a month before moving to amend. (Docket # 55 at 2.) A plaintiff may amend their complaint once as a matter of course (within certain parameters). Fed. R. Civ. P. 15(a)(1). After that, a plaintiff must ask for—and be granted— the court’s leave. Fed. R. Civ. P. 15(a)(2). Alternatively, a plaintiff can seek the opposing party’s consent. Id. Leave to amend should be freely given by the court. Fed. R. Civ. P. 15(a)(2); Indep. Trust Corp. v. Stewart Info. Servs. Corp., 665 F.3d 930, 943 (7th Cir. 2012); Johnson v. Cypress Hill, 641 F.3d 867, 871–72 (7th Cir. 2011). But a court may deny leave to file an amended complaint in the case of undue delay; bad faith or dilatory motive on the part of the movant; repeated failure to cure deficiencies by amendments previously allowed;

undue prejudice to the opposing party by virtue of allowance of the amendment; or where the amendment would be futile. Hukic v. Aurora Loan Servs., 588 F.3d 420, 432 (7th Cir. 2009); Arreola v. Godinez, 546 F.3d 788, 796 (7th Cir. 2008). I do not find that McDougal’s motion to amend his complaint is made in bad faith or an attempt to delay his complaint. He has not previously moved to amend. However, I do find that allowing McDougal to amend his complaint would be futile, at least in part. A proposed amendment is futile where it would not survive a motion to dismiss. Moore v. State of Ind., 999 F.2d 1125, 1128 (7th Cir. 1993). A case will not survive a motion to dismiss where it does not “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 (2008). 2 McDougal proposes to add the Milwaukee County Jail and Armor Correctional Health Services as defendants, neither of which he can add. First, the jail is not a proper defendant because it cannot be sued. Section 1983 allows a plaintiff to sue a “person” who, acting under color of law, violates his constitutional rights. The jail is not a person. It is not

an individual subject to suit under §1983. It is true that under some circumstances, a municipality—which is not a person—may be sued under § 1983. See Monell v. Dep’t of Social Serv’s of City of New York, 436 U.S. 658 (1978). But Federal Rule of Civil Procedure 17(b) says that a defendant in a federal lawsuit must have the legal capacity to be sued. State law determines whether an entity has that capacity. Webb v. Franklin County Jail, Case No. 16-cv- 1284, 2017 WL 914736 at *2 (S.D. Ill. Mar. 8, 2017). In Wisconsin, the jail is an arm of the sheriff’s department. Under Wisconsin law, the sheriff’s department is an arm of the County. See Abraham v. Piechowski, 13 F. Supp.2d 870, 877-79 (E.D. Wis. 1998). This means that neither the jail nor the sheriff’s department are “legal entit[ies] separable from the

county government which [they] serve[] . . . .” Whiting v. Marathon C’nty Sheriff’s Department, 382 F.3d 700, 704 (7th Cir. 2004)). Second, McDougal could sue Armor, but only in limited circumstances. McDougal states he wants to sue Armor because it was “responsible for the medical treatment . . . of all the inmates at [the] Jail.” (Docket # 53-2 at 2.) However, there is no employer liability based on respondeat superior under § 1983. Monell v. Department of Social Services of City of New York, 436 U.S. 658, 691 (1978). That is, Monell holds that a municipal entity or a related corporate entity like Armor can be liable under § 1983, but not simply because its employees violated a plaintiff’s constitutional rights. Id. at 694. Instead, a municipality or, in this

instance, Armor, can be liable for a constitutional violation only when the violation is 3 brought about by (1) its express policy, (2) a widespread, though unwritten, custom or practice, or (3) a decision by an agent with “final policymaking authority.” Darchak v. City of Chicago Bd. of Educ., 580 F.3d 622, 629 (7th Cir. 2009). McDougal’s proposed amended complaint does not contain any allegations that he did not receive adequate medical care

because of a policy or practice or a decision by a policymaker. Therefore, Armor is not a proper defendant. McDougal also asks to add Samantha R. Markwardt as a defendant. However, he does not need to amend his complaint to do so. He initially sued a “Nurse Samantha.” When the United States Marshal Service was unable to locate a “Nurse Samantha” for service and McDougal could not identify her either, I substituted a Jane Doe placeholder for Nurse Samantha. (Docket # 30.) I instructed him to use discovery to identify her and then file a motion to substitute once he found her identity. (Id., Docket # 38 at 1.) McDougal did file a letter identifying her. (Docket # 49.) However, the letter—rather than a motion to

substitute—did not alert the court to take action to add Markwardt to the case and serve her.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Johnson v. Cypress Hill
641 F.3d 867 (Seventh Circuit, 2011)
Darchak v. City of Chicago Board of Education
580 F.3d 622 (Seventh Circuit, 2009)
Hukic v. Aurora Loan Services
588 F.3d 420 (Seventh Circuit, 2009)
Arreola v. Godinez
546 F.3d 788 (Seventh Circuit, 2008)
Abraham v. Piechowski
13 F. Supp. 2d 870 (E.D. Wisconsin, 1998)

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McDougal v. Penn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcdougal-v-penn-wied-2020.