Murphy v. Hughes

District Court, S.D. Illinois·Decided June 26, 2024·No. 3:24-cv-00107·Unknown

Opinion

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

STEVEN MURPHY, # M04196, ) ) Plaintiff, ) vs. ) Case No. 24-cv-00107-RJD ) LATOYA HUGHES, ) JON LOFTUS, and ) ANTHONY WILLS, ) ) Defendants. )

MEMORANDUM AND ORDER

DALY, Magistrate Judge: Plaintiff Steven Murphy, an inmate of the Illinois Department of Corrections (“IDOC”) currently incarcerated at Menard Correctional Center, filed the instant lawsuit pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. He asserts that Defendants denied him protective custody, after which he was attacked by another inmate and sustained injuries. (Doc. 1). Plaintiff seeks monetary damages. Id. This case is now before the Court for preliminary review of the Complaint under 28 U.S.C. § 1915A,1 which requires the Court to screen prisoner Complaints to filter out nonmeritorious claims. 28 U.S.C. § 1915A(a). Any portion of the Complaint that is legally frivolous, 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). The Complaint Plaintiff makes the following allegations in the Complaint (Doc. 1): Plaintiff made

1 The Court has jurisdiction to screen the Complaint due to Plaintiff’s consent to the full jurisdiction of a Magistrate Judge (Doc. 5), and the limited consent to the exercise of Magistrate Judge jurisdiction as set forth in the Memorandum of Understanding between this Court and the IDOC. requests to be placed in Protective Custody (“PC”) dating back to August 2021, because he believed his life was in danger. (Doc. 1, pp. 9, 26). Defendants Wills (Menard Warden), Hughes (Acting IDOC Director) and Loftus (Administrative Review Board) refused to grant the PC requests, due to “staff retaliation” for Plaintiff’s litigation and grievance activity, and due to

negligence on their parts. (Doc. 1, p. 9). On or about September 22, 2023, Plaintiff was being moved to the PC “kick-out/denial yard,” when he was attacked by another inmate who had also been denied PC. (Doc. 1, pp. 9, 35). Plaintiff sustained a broken thumb that required surgery, as well as a swollen eye and busted lip. After the fight, Plaintiff was maced and sent to segregation, where he was not given any medical treatment for four days, despite submitting multiple medical request slips and asking for a crisis team. Plaintiff eventually had surgery for the left thumb fracture; he now has a plate and screws in his thumb, a large scar, some loss of mobility, and “constant aching pain” from the surgery. He sues each Defendant in their personal and official capacities. (Doc. 1, p. 10).

Based on the allegations in the Complaint, the Court designates the following claims in this pro se action: Count 1: Eighth Amendment failure to protect claim against Hughes, Loftus, and Wills, for denying Plaintiff’s request to be housed in Protective Custody.

Count 2: State law negligence claim against Hughes, Loftus, and Wills, for denying Plaintiff’s request to be housed in Protective Custody.

Count 3: First Amendment retaliation claim against Hughes, Loftus, and Wills, for denying Plaintiff’s PC request because he filed lawsuits and grievances against them and against other IDOC staff members.

Count 4: Eighth Amendment deliberate indifference claim against Hughes, Loftus, and Wills, for delaying medical attention for Plaintiff’s injuries sustained in the September 22, 2023 attack. Any other claim that is mentioned in the Complaint but not addressed in this Order should be considered dismissed without prejudice as inadequately pled under the Twombly pleading standard.2 Discussion Count 1 “[P]rison officials have a duty . . . to protect prisoners from violence at the hands of other prisoners.” Farmer v. Brennan, 511 U.S. 825, 833 (1994) (internal citations omitted); see also Pinkston v. Madry, 440 F.3d 879, 889 (7th Cir. 2006). To state an Eighth Amendment claim for failure to protect, a plaintiff must plead facts suggesting he is incarcerated under conditions posing

a substantial risk of serious harm, and that the defendants acted with “deliberate indifference” to that danger. Id.; Pinkston, 440 F.3d at 889. Typically, the plaintiff must show that he complained to prison officials about a specific and credible danger to his safety. See Santiago v. Walls, 599 F.3d 749, 758-59 (7th Cir. 2010); Pope v. Shafer, 86 F.3d 90, 92 (7th Cir. 1996). The Complaint does not disclose any details about what reasons Plaintiff gave Defendants for why he requested PC placement, or whether Plaintiff alerted them that the inmate who ultimately attacked him posed a danger to his safety. Nonetheless, at this early stage, Plaintiff’s allegations in Count 1 are sufficient to proceed against Hughes, Loftus, and Wills, each of whom concurred in the decision to reject his PC request. (Doc. 1, p. 26).

Count 2 Plaintiff asserts that Defendants’ denial of his PC request amounted to negligence as well as a constitutional violation. Under Illinois law, a complaint may state a claim for negligence if

2 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 that is plausible on its face.”). the plaintiff alleges facts showing that the defendant owed the plaintiff a duty of care, breached that duty, and that the breach was the proximate cause of the plaintiff’s injury. Thompson v. Gordon, 948 N.E.2d 39, 45 (Ill. 2011) (citing Iseberg v. Gross, 879 N.E.2d 278 (2007)). Plaintiff’s negligence claim is based on the same facts that support the Eighth Amendment claim in Count 1.

Therefore, the Court has supplemental jurisdiction to consider the claim of negligence. See 28 U.S.C. § 1367(a); Wisconsin v. Ho-Chunk Nation, 512 F.3d 921, 936 (7th Cir. 2008) (state claims must “derive from a common nucleus of operative fact” with the federal claims). Count 2 may also proceed against Hughes, Loftus, and Wills. Count 3 Prison officials may not retaliate against inmates for filing grievances, lawsuits, or otherwise complaining about their conditions of confinement. See, e.g., Gomez v. Randle, 680 F.3d 859, 866 (7th Cir. 2012); Walker v. Thompson, 288 F.3d 1005 (7th Cir. 2002). The issue in a retaliation claim is whether the plaintiff experienced an adverse action that would likely deter First Amendment activity in the future, and if the First Amendment activity was “at least a motivating

factor” in the defendants’ decision to take the retaliatory action. See McKinley v. Schoenbeck, 731 F.

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

Murphy v. Hughes, (S.D. Ill. 2024).

Murphy v. Hughes (Murphy v. Hughes) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Santiago v. Walls
599 F.3d 749 (Seventh Circuit, 2010)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Romanelli, Ronald v. Suliene, Dalia
615 F.3d 847 (Seventh Circuit, 2010)
Jose Zurita v. Richard Hyde
665 F.3d 860 (Seventh Circuit, 2011)
Gregory Pope v. Stephen Shafer
86 F.3d 90 (Seventh Circuit, 1996)
Tony Walker v. Tommy G. Thompson
288 F.3d 1005 (Seventh Circuit, 2002)
Gomez v. Randle
680 F.3d 859 (Seventh Circuit, 2012)
Jurijus Kadamovas v. Michael Stevens
706 F.3d 843 (Seventh Circuit, 2013)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Bridges v. Gilbert
557 F.3d 541 (Seventh Circuit, 2009)
Wisconsin v. Ho-Chunk Nation
512 F.3d 921 (Seventh Circuit, 2008)
Iseberg v. Gross
879 N.E.2d 278 (Illinois Supreme Court, 2007)
Thompson v. Gordon
948 N.E.2d 39 (Illinois Supreme Court, 2011)
Miguel Perez v. James Fenoglio
792 F.3d 768 (Seventh Circuit, 2015)
Ashoor Rasho v. Willard Elyea
856 F.3d 469 (Seventh Circuit, 2017)