Mitchell v. Zaiz

CourtDistrict Court, S.D. Illinois
DecidedApril 19, 2023
Docket3:22-cv-02318
StatusUnknown

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

Bluebook
Mitchell v. Zaiz, (S.D. Ill. 2023).

Opinion

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

JEREMY MITCHELL, #466864, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-02318-JPG ) ST. CLAIR COUNTY COURTHOUSE, ) ST. CLAIR COUNTY CLERK’S OFFICE, ) and MARIE ZAIZ, ) ) Defendants. )

MEMORANDUM AND ORDER

GILBERT, District Judge: Plaintiff Jeremy Mitchell, an inmate in the custody of the Illinois Department of Corrections and currently incarcerated at Shawnee Correctional Center, filed this action pro se pursuant to 42 U.S.C. § 1983 against St. Clair County’s Courthouse, Clerk’s Office, and Clerk. In the Complaint, Plaintiff claims that the defendants interfered with his ability to appear and file an answer in St. Clair County Case Nos. 21-FA-0036 (seizure case) and 21-MR-0141 (forfeiture case) and thereby delayed his cases. (Doc. 1, pp. 1-47). He seeks money damages and injunctive relief, in the form of an order terminating the Clerk’s employment and enforcing his “right to be heard” in the St. Clair County cases. (Id. at 8). The Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner Complaints and filter out non-meritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Complaint that is legally frivolous or malicious, fails to state a claim for relief, or requests money damages from an immune defendant must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations are liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). The Complaint Plaintiff sets forth the following allegations in the Complaint (Doc. 1, p. 5): Plaintiff received a Notice of Seizure and Intent to Forfeit $7,360.00 and two 1894 gold coins, after he was arrested and detained at St. Clair County Jail on May 25, 2021. Clerk Zaiz would not accept his

answer in St. Clair County Case Nos. 21-FA-0036 (seizure case) or 21-MR-0141 (forfeiture case) without payment of an “answer filing fee.” However, the clerk also refused to tell Plaintiff the amount of the fee. Plaintiff was scheduled to appear at a Zoom teleconference on June 1, 2021. Although he informed jail officials about the hearing in his St. Clair County cases, they made no effort to ensure his appearance. On June 10, 2021, a judge signed an Order Finding Probable Cause That Property May Be Subject to Forfeiture based on his failure to appear at the hearing. (Id. at 5, 9). Plaintiff complains that the defendants’ misconduct “‘prolonged’ his case and his right to be heard.” (Id.). Discussion Based on the allegations, the Court designates two claims in this pro se Complaint:

Count 1: Defendant Clerk Zaiz interfered with Plaintiff’s access to the courts by refusing to accept his answer in St. Clair County Case Nos. 21- FA-0036 and 21-MR-0141 without a filing fee and also refusing to disclose the amount of the fee, in violation of his rights under the Fourth, Eighth, and/or Fourteenth Amendment(s).

Count 2: Defendants interfered with Plaintiff’s access to the courts when they failed to facilitate his appearance at a Zoom teleconference in St. Clair County Case Nos. 21-FA-0036 and 21-MR-0141 on or around June 1, 2021 and delayed both cases, in violation of his rights under the Fourth, Eighth, and/or Fourteenth Amendment(s).

Any other claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.1

1 See Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (an action fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face”). Plaintiff filed this civil rights action pursuant to 42 U.S.C. § 1983 for constitutional deprivations stemming from interference with his access to the courts in St. Clair County Case Nos. 21-FA-0036 (seizure case) and 21-MR-0141 (forfeiture case). Detainees and convicted prisoners, alike, possess a fundamental right of “meaningful” access to the courts. Bounds v. Smith,

430 U.S. 817 (1977); Casteel v. Pieschek, 3 F.3d 1050, 1053 (7th Cir. 1993). When presented with a claim for denial of court access, the district court employs a two-part test. Smith v. Shawnee Library Sys., 60 F.3d 317 (7th Cir. 1995); Jenkins v. Lane, 977 F.2d 266, 268 (7th Cir. 1992). First, a plaintiff must show that each defendant failed “to assist in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.” Jenkins, 977 F.2d at 268 (quoting Bounds, 430 U.S. at 828). Second, the plaintiff must show “some quantum of detriment caused by the challenged conduct of state officials resulting in the interruption and/or delay of plaintiff’s pending or contemplated litigation.” Alston v. DeBruyn, 13 F.3d 1036, 1041 (7th Cir. 1994). Count 1

As for the first component of this claim against the clerk, Plaintiff asserts that Clerk Zaiz would not file his answer without the appropriate filing fee but also withheld information about the amount of the fee he was required to pay. It is not at all clear whether Clerk Zaiz unlawfully interfered with Plaintiff’s court access when she demanded payment of the fee, in the correct amount, at the time of accepting the answer. It is also unclear whether she withheld information about the filing fee that was otherwise unavailable. Plaintiff’s allegations are threadbare. As for the second component of this claim, Plaintiff must describe some detriment in support of his claim for denial of court access. Plaintiff alleges that he suffered a violation of his “right to be heard” which “prolonged” proceedings. (Id. at 5). In other words, he describes a delay in his seizure and forfeiture cases. Although “[a] delay or interruption in pending or contemplated litigation may indicate a deprivation of constitutional dimensions,” a plaintiff must show prejudice. Kinkaid v. Vail, 969 F.2d 594 (7th Cir. 1992). Plaintiff has identified no prejudice caused by the Clerk’s conduct, such as the actual forfeiture of his property. Even at this early stage in litigation,

Plaintiff must allege prejudice that resulted from the interference with his court access. Even if Plaintiff alleges prejudice, however, the clerk may be entitled to absolute immunity. This case is similar to Kinkaid v. Vail, 969 F.2d 594 (7th Cir. 1992), a § 1983 suit brought by a group of inmates against state court clerks who returned their complaints unfiled. The clerks did so, first, because the wrong filing fee was paid, and, second, because the complaints belonged in small claims court. Id.

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Related

Bounds v. Smith
430 U.S. 817 (Supreme Court, 1977)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Byron Alston v. H. Christian Debruyn
13 F.3d 1036 (Seventh Circuit, 1994)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Casteel v. Pieschek
3 F.3d 1050 (Seventh Circuit, 1993)

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Bluebook (online)
Mitchell v. Zaiz, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-zaiz-ilsd-2023.