McGraw v. Downey

CourtDistrict Court, C.D. Illinois
DecidedMay 30, 2023
Docket2:22-cv-02251
StatusUnknown

This text of McGraw v. Downey (McGraw v. Downey) 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
McGraw v. Downey, (C.D. Ill. 2023).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS URBANA DIVISION

ANDRE HUNTER MCGRAW, ) Plaintiff, ) ) v. ) Case No. 22-cv-02251 ) MICHAEL DOWNEY, ) Defendant. )

ORDER COLLEEN R. LAWLESS, United States District Judge: Before the Court for screening is a Complaint (Doc. 1) filed under 42 U.S.C § 1983 by Plaintiff Andre Hunter McGraw, who is currently detained at Jerome Combs Detention Center (”JCDC”). Plaintiff has also filed Motions for Counsel. (Doc. 5, 9.) I. Complaint A. Screening Standard The Court must “screen” Plaintiff’s Complaint and dismiss any legally insufficient claim or the entire action if warranted. 28 U.S.C. § 1915A. A claim is legally insufficient if it “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. In reviewing the complaint, the court accepts the factual allegations as accurate, liberally construing them in the plaintiff’s favor. Turley v. Rednour, 729 F.3d 645, 649 (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 omitted).

B. Factual Allegations In August 2022, Plaintiff feared for his life after another detainee took Plaintiff’s property and told Plaintiff he was not returning the items. Plaintiff submitted three inmate request forms explaining the detainee’s acts. About ten days later, the detainee threw urine in Plaintiff’s cell. Plaintiff again submitted an inmate request outlining the detainee’s actions and requested to be moved. Two JCDC officials told Plaintiff he was

being transferred to a different housing area of JCDC. Plaintiff asked to be moved into protective custody because he had “problems” with the location of the proposed move. (Doc. 1 at 5.) The officials told Plaintiff no space was available in protective custody. Plaintiff asked to be moved to administrative segregation “to prevent being injured [by] other inmates.” (Id. at 6.) The officials moved Plaintiff to the area they initially intended.

Sometime later, three other detainees wrestled Plaintiff to the ground and hit, bit, and threatened to kill Plaintiff. As a result, Plaintiff suffered a head wound. After Plaintiff returned from receiving stitches at a local hospital, correction officials Leduke, Menenga, Peach, Slueinski, and Taylor refused Plaintiff’s request to be moved to protective custody. Plaintiff also claims that after he returned from the hospital, “they

never tested me for sexual diseases from [the] bite” he suffered. (Id.) C. Analysis State officials must “take reasonable measures to guarantee the safety of the inmates.” Hudson v. Palmer, 468 U.S. 517, 526–27 (1984). “[T]o state a viable failure-to- protect claim under the Fourteenth Amendment, a pretrial detainee must allege: (1) the defendant made an intentional decision regarding the conditions of the plaintiff’s

confinement; (2) those conditions put the plaintiff at substantial risk of suffering serious harm; (3) the defendant did not take [reasonably] available measures to abate the risk, even though a reasonable officer in the circumstances would have appreciated the high degree of risk involved, making the consequences of the defendant’s inaction obvious; and (4) the defendant, by not taking such measures, caused the plaintiff’s injuries.” Thomas v. Dart, 39 F.4th 835, 841 (7th Cir. 2022).

Under Federal Rule of Civil Procedure 8(a), a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “This requirement is satisfied if the complaint (1) describes the claim in sufficient detail to give the defendant fair notice of what the claim is and the grounds upon which it rests and (2) plausibly suggests that the plaintiff has a right to relief

above a speculative level.” Bravo v. Midland Credit Mgmt., 812 F.3d 599, 601–02 (7th Cir. 2016). Plaintiff names Kankakee County Sheriff Michael Downey as a Defendant but does not mention Downey in his Complaint or, more importantly, state the specific acts or omissions to infer a constitutional violation against Downey. See Collins v. Kibort, 143

F.3d 331, 334 (7th Cir. 1998) (“A plaintiff cannot state a claim against a defendant by including the defendant’s name in the caption.”). Therefore, Plaintiff fails to state a claim against Defendant Downey. The Court notes that Plaintiff mentions correction officials Leduke, Menenga, Peach, Slueinski, and Taylor but does not name them as Defendants. Even if he had,

Plaintiff’s account is insufficient to state a failure to protect claim against them. Plaintiff claims that after the three detainees attacked him but before being transported to a local hospital for medical care, Leduke, Menenga, Peach, Slueinski, and Taylor denied Plaintiff’s request to place him in protective custody. However, Plaintiff does not state that upon his return to JCDC, he was located near his attacker or subjected to further harm based on the denial of his earlier request. See Giles v. Tobeck, 895 F.3d 510, 513 (7th

Cir. 2018) (“[T]he official’s response must be so inadequate that it amounts to a reckless disregard for the risk and ‘effectively condones the attack.’”) (quoting Santiago v. Walls, 599 F.3d 749, 756 (7th Cir. 2010)). The objective-reasonableness standard for a pretrial detainee’s claim for inadequate medical care in violation of due process rights under the Fourteenth

Amendment requires that the court focus on the totality of facts and circumstances in the case and gauge objectively—without regard to any subjective belief held by the individual—whether the response was reasonable. McGee v. Parsamo, 55 F.4th 563, 569 (7th Cir. 2022). Plaintiff does not state a claim under the Fourteenth Amendment for not

receiving medical testing as he does not provide any facts or describe the circumstances that would permit the Court to analyze whether an official’s response was objectively unreasonable. Accordingly, the Court dismisses Plaintiff’s Complaint, concluding that he fails to state a claim for relief. Despite the Court’s dismissal, the Court grants Plaintiff leave to file an amended complaint. If Plaintiff elects to file an amendment, that filing must contain a “short and

plain statement of the claim showing that [he] is entitled to relief[.]” Fed. R. Civ. P. 8(a)(2). The Court does not accept piecemeal amendments. Plaintiff’s amended complaint must stand independently without reference to his initial filing and contain all claims against all defendants.

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Related

Santiago v. Walls
599 F.3d 749 (Seventh Circuit, 2010)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Gregory Turley v. Dave Rednour
729 F.3d 645 (Seventh Circuit, 2013)
Michael Alexander v. United States
721 F.3d 418 (Seventh Circuit, 2013)
Katiuska Bravo v. Midland Credit Management, Inc
812 F.3d 599 (Seventh Circuit, 2016)
Marvin Thomas v. Thomas Dart
39 F.4th 835 (Seventh Circuit, 2022)
Giles v. Tobeck
895 F.3d 510 (Seventh Circuit, 2018)

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Bluebook (online)
McGraw v. Downey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcgraw-v-downey-ilcd-2023.