Oaks v. Jackson County Jail

CourtDistrict Court, S.D. Illinois
DecidedJune 22, 2023
Docket3:22-cv-02435
StatusUnknown

This text of Oaks v. Jackson County Jail (Oaks v. Jackson County Jail) 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
Oaks v. Jackson County Jail, (S.D. Ill. 2023).

Opinion

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

BACAREE OAKS, 20160-156, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-02435-JPG ) JACKSON COUNTY JAIL, ) GREG ROWALD, ) and DEA AGENTS, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Bacaree Oaks brings this action pursuant to 42 U.S.C. § 1983 and 28 U.S.C. § 1331 for deprivations of his due process rights at Jackson County Jail. (Doc. 1). In his Complaint, Plaintiff claims he was taken into custody by federal and local officials pursuant to a state warrant for his arrest on October 27, 2021. (Id. at 2-6). Officer Greg Rowald informed Plaintiff that he would not be processed at the Jail, served with a federal complaint, allowed to contact an attorney, or given permission to post bond until he spoke with a Drug Enforcement Agent, which occurred two days later. (Id.). He seeks monetary relief for the alleged violations of his due process rights resulting from this delay. (Id. at 6). 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). Discussion Based on the allegations in the pro se Complaint, the Court finds it convenient to designate a single claim in this action: Count 1: Defendants violated Plaintiff’s right to due process of law under the Fifth or Fourteenth Amendment by arresting him pursuant to a state warrant and then delaying his processing at the Jail, service with a federal complaint, access to phone calls with an attorney, and permission to post bond until he spoke with Drug Enforcement Agents from October 27-29, 2021.

Any other claim that is mentioned in the Complaint but not addressed herein is considered dismissed without prejudice as inadequately pled under Twombly.1 Jackson County Jail and DEA Agents Section 1983 and Bivens both create a cause of action based on personal liability and predicated upon fault. Pepper v. Village of Oak Park, 430 F.3d 809, 810 (7th Cir. 2005) (§ 1983); Del Raine v. Williford, 32 F.3d 1024, 1047 (7th Cir. 1994) (Bivens). The doctrine of respondeat superior does not apply in either context. Id. In order to establish liability, an individual defendant must have caused or participated in a constitutional deprivation. Id. In other words, Plaintiff must identify particular defendants and describe the acts or omissions that caused a violation of his federally protected rights. He must draw a connection between each defendant and his own constitutional deprivation. Merely listing potential defendants in the case caption is not enough to state a claim against them. Plaintiff lists Jackson County Jail and DEA Agents as defendants but sets forth no allegations or claims against them. Plaintiff does not describe what they did, or failed to do, in violation of his rights. The Court is unable to guess. Plaintiff must provide some context for his

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”). claims against each one. He has not done so in the body of his Complaint, so Count 1 shall be dismissed against Jackson County Jail and DEA Agents without prejudice. Moreover, Jackson County Jail is not a “person” subject to suit under § 1983 or Bivens. Plaintiff’s designation of the county jail may represent an attempt to hold the county liable for his injuries. See Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 690, 694 (1978). However,

municipal liability arises from the execution of a government policy or custom that causes a constitutional injury. Id. Plaintiff points to no policy or custom that caused his injuries to occur. Accordingly, no Monell claim survives screening, either. Greg Rowald Greg Rowald is the only defendant who is both named as a defendant and allegedly involved in the events giving rise to this action. Plaintiff claims that Rowald detained him for two days without processing him at the Jail, serving him with a federal complaint, allowing him to speak with counsel, or allowing him to post bond until he spoke with DEA agents. Because he is a local official, the claim against him arises under § 1983 and not Bivens. To state a claim under

§ 1983, a plaintiff must show that: (1) the complained of conduct was committed by a person acting under color of state law; and (2) the conduct deprived the plaintiff of rights, privileges, or immunities secured by the Constitution or laws of the United States. Panfil v. City of Chicago, 45 Fed. Appx. 528, 532 (7th Cir. 2002) (citations omitted). The Complaint includes insufficient allegations to support a due process claim. The Seventh Circuit has held that no due process violation occurs where a person is arrested pursuant to a valid arrest warrant and held for a short time, such as the two-day period that Plaintiff describes. See, e.g., Brown v. Patterson, 823 F.2d 167, 169 (7th Cir. 1978) (no due process violation arose from detention of wrong individual for 24 hours); Baker v. McCollan, 443 U.S. 137 (1979) (no due process violation arose from two-day detention of wrong twin brother pursuant to valid arrest warrant); Panfil, 45 Fed. Appx. at 532 (no due process violation arose from two-day detention and four-day detention of wrong twin brother arrested pursuant to valid warrant, over protests of the arrestee). After all, “the Constitution does not guarantee that only the guilty will be arrested. If it did, § 1983 would provide a cause of action for every defendant acquitted—indeed,

for every suspect released.” Baker, 443 U.S. at 145. The allegations also support no Fourteenth Amendment due process claim against Rowald for the denial of Plaintiff’s request to post bond. This claim is undeveloped. Plaintiff did not indicate when he requested permission to post bond, whether and how often he directed the request to Rowald, and the length of the delay in actually posting bond. Similarly, the Complaint lacks facts necessary to analyze Plaintiff’s related claim for denial of access to an attorney. When presented with a Sixth or Fourteenth Amendment claim for denial of the right to counsel, a court must determine: (1) whether the right to counsel attached at the time of the statement or proceeding at issue; (2) if so, whether the accused executed a valid waiver of

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Related

Brewer v. Williams
430 U.S. 387 (Supreme Court, 1977)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Anthony A. Brown v. Officer L. Patterson
823 F.2d 167 (Seventh Circuit, 1987)
United States v. Rodney Spruill
296 F.3d 580 (Seventh Circuit, 2002)
Pruitt v. Mote
503 F.3d 647 (Seventh Circuit, 2007)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Walden v. City of Chicago
391 F. Supp. 2d 660 (N.D. Illinois, 2005)
Del Raine v. Williford
32 F.3d 1024 (Seventh Circuit, 1994)
Panfil v. City of Chicago
45 F. App'x 528 (Seventh Circuit, 2002)

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Oaks v. Jackson County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oaks-v-jackson-county-jail-ilsd-2023.