Noland v. Tharp

CourtDistrict Court, S.D. Illinois
DecidedNovember 12, 2021
Docket3:21-cv-01000
StatusUnknown

This text of Noland v. Tharp (Noland v. Tharp) 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
Noland v. Tharp, (S.D. Ill. 2021).

Opinion

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

KADEEM NOLAND, #Y47451, ) ) Plaintiff, ) ) vs. ) Case No. 21-cv-01000-JPG ) KRISTOPHER THARP ) and PAUL SARHAGE, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Kadeem Noland filed this civil rights action pursuant to 42 U.S.C. § 1983 for constitutional deprivations that resulted from his punishment with a thirty day lockdown and commissary restriction during his pretrial detention at Madison County Jail (“Jail”).1 (See Doc. 2). He asserts claims against the defendants for violating his right to due process of law and denying him access to the courts. (Id.). Plaintiff seeks monetary relief against the defendants. (Id. at 7). The Complaint is now before the Court for preliminary review under 28 U.S.C. § 1915A, which requires the Court to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a). Any portion of a complaint that is legally frivolous or malicious, fails to state a claim upon which relief may be granted, or asks for money damages from an immune defendant must be dismissed. See 28 U.S.C. § 1915A(b). The factual allegations of the pro se complaint are liberally construed at this stage. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009).

1 Noland originally filed this action with several co-plaintiffs. See Evans, et al. v. Tharp, et al., Case No. 21-cv-905-JPG (S.D. Ill.). Pursuant to a Memorandum and Order dated August 17, 2021, the Court severed his claims into this separate suit. (Doc. 1). The Complaint Plaintiff sets forth the following allegations in the Complaint (see Doc. 2): On July 29, 2021, Plaintiff’s entire cell block at Madison County Jail was placed on lockdown when Lieutenant Sarhage smelled smoke. (Id. at 6). Without investigating the matter, issuing any disciplinary tickets, or conducting a disciplinary hearing, all detainees in the block were punished

with a thirty day lockdown and commissary restriction. For some of this time, inmates could not purchase stamps and other supplies. (Id.). Two weeks before the incident, Captain Tharp issued a memorandum to notify detainees that staff recently observed inmates attempting to start “small fires.” (Doc. 2, p. 9). The captain made it clear that this conduct would not be tolerated. (Id.). He instructed detainees to report such incidents immediately, and he warned them that failing to do so would result in a “non-negotiable thirty (30) day lockdown of the block where the incident occurs,” as well as a loss of commissary privileges for the same time period. (Id.). He added that this thirty day punishment was only a starting point and could be extended. (Id.).

When several inmates filed grievances to complain about their punishment in July and August 2021, Captain Tharp instructed detainees not to “waste my time or yours writing me telling me how unfair things are [because] [t]here will be no discussion on the matter.” (Id. at 6). Captain Tharp emphasized that his top priority was the safety of the inmates. Discussion Based on the allegations, the Court finds it convenient to designate two (2) counts in the pro se Complaint: Count 1: Fourteenth Amendment claim against Defendants Sarhage and Tharp for depriving Plaintiff of a protected liberty interest without due process of law by punishing him with a thirty day lockdown and commissary restriction after Sarhage smelled smoke in the cell block on or around July 29, 2021.

Count 2: First and/or Fourteenth Amendment claim against Defendants Sarhage and Tharp for depriving Plaintiff of access to the courts by denying him stamps for use in contacting an attorney beginning on or around July 29, 2021.

Any claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice under Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). Count 1 A Fourteenth Amendment due process claim arises when the state deprives a person of a constitutionally protected interest in “life, liberty, or property” without due process of law. Zinermon v. Burch, 494 U.S. 113, 125 (1990). Any “nontrivial punishment of a person not yet convicted” is a sufficient deprivation of liberty to give rise to due process protections. See Holly v. Woolfolk, 415 F.3d 678, 679-80 (7th Cir. 2005) (collecting cases). A pretrial detainee cannot be placed in segregation or lockdown segregation as punishment for a disciplinary infraction without notice and an opportunity to be heard; due process requires no less. Rapier v. Harris, 172 F.3d 999, 1004-05 (7th Cir. 1999). With that said, a person who is lawfully detained in pretrial confinement is nevertheless subject to certain restrictions on his liberty. See Rapier, 172 F.3d at 1003. The government may take reasonable measures to effectuate pretrial detention, and this includes steps necessary to maintain safety and security at the facility. Id. As long as these measures are reasonably related to the orderly management of the facility, they are not considered punishment for the crime the detainee is charged with committing. Id. Whether Plaintiff’s placement in lockdown and commissary restrictions amounted to punishment, triggering due process protections, or merely a managerial decision, triggering no such protections, is not altogether clear at this stage. Captain Tharp’s memo refers to small fires that inmates were caught starting in early July 2021, and it threatens consequences for failing to report future attempts to start fires. (Doc. 2, p. 9). Plaintiff’s Complaint characterizes the lockdown and commissary restrictions as “punishment” for the smell of smoke on July 29, 2021. (Id. at 6). Given that his placement in lockdown and commissary restrictions lasted thirty days—

a far longer period of time than would typically be associated with an investigation into the smell of smoke—it appears that he may have been subject to punishment. And, according to Plaintiff, he received no due process protections, such as notice or a hearing, before or after the punishment occurred. At this stage, Count 1 shall be allowed to proceed against both defendants.2 Count 2 Convicted persons and pretrial detainees alike have a fundamental right of meaningful access to the courts. Bounds v. Smith, 430 U.S. 817 (1977) (convicted persons); Casteel v. Pieschek, 3 F.3d 1050, 1053 (7th Cir. 1993) (pretrial detainees). A claim for denial of access to the courts involves two components. Smith v. Shawnee Library Sys., 60 F.3d 317 (7th Cir. 1995);

Jenkins v. Lane, 977 F.2d 266, 268 (7th Cir. 1992).

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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)
Christopher Holly v. D. Woolfolk
415 F.3d 678 (Seventh Circuit, 2005)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Marion v. Columbia Correctional Institution
559 F.3d 693 (Seventh Circuit, 2009)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)
Maurice Hardaway v. Brett Meyerhoff
734 F.3d 740 (Seventh Circuit, 2013)
Casteel v. Pieschek
3 F.3d 1050 (Seventh Circuit, 1993)

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Noland v. Tharp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/noland-v-tharp-ilsd-2021.