Payne v. Crooks

CourtDistrict Court, S.D. Illinois
DecidedOctober 7, 2025
Docket3:25-cv-01013
StatusUnknown

This text of Payne v. Crooks (Payne v. Crooks) 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
Payne v. Crooks, (S.D. Ill. 2025).

Opinion

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

KRAIG PAYNE, Y40610, ) ) Plaintiff, ) ) vs. ) Case No. 25-cv-1013-DWD ) C/O CROOKS, ) JEREMIAH BROWN, ) ) Defendants. )

MEMORANDUM AND ORDER

DUGAN, District Judge: Plaintiff Kraig Payne, an inmate of the Illinois Department of Corrections (IDOC) currently detained at Lawrence Correctional Center (Lawrence), brings this civil rights action pursuant to 42 U.S.C. § 1983 for alleged deprivations of his constitutional rights. Plaintiff alleges the defendants failed to protect him from an assault by a fellow inmate. Plaintiff’s Complaint (Doc. 1) was dismissed for failure to state a claim, and his amended complaint (Doc. 12) is now before the Court for preliminary review pursuant to 28 U.S.C. § 1915A. Under Section 1915A, the Court is required to screen prisoner complaints to filter out non-meritorious claims. See 28 U.S.C. § 1915A(a)-(b). Any portion of a complaint that is legally frivolous, malicious, fails to state a claim upon which relief may be granted, or asks for money damages from a defendant who by law is immune from such relief must be dismissed. 28 U.S.C. § 1915A(b). At this juncture, the factual allegations of the pro se complaint are to be liberally construed. Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816, 821 (7th Cir. 2009). ANALYSIS Plaintiff again alleges that on September 30, 2024, a “hostile detainee” approached him during yard time for his housing unit. (Doc. 12 at 6). He claims that Defendant

Crooks allowed the inmate to “walk up on [him]” but simply closed the gate and walked away instead of intervening. Crooks then sat at the door overlooking the tier, where he could see Plaintiff and the hostile inmate “getting ready to fight.” Plaintiff complains Crooks did nothing, a fight ensued, and he sustained a “deadly face scratch.” He sought medical care via a sick call slip, but got no response. Plaintiff alleges Crooks is liable for

failing to act, and a supervisor could be sued for failing to ensure health and safety problems. (Id.). He goes on to allege that Defendant Jeremiah Brown, the warden, is liable for failing to respond to his complaint about serious pain. (Doc. 12 at 5). He alleges a supervisor created a policy or custom allowing or encouraging illegal acts. He claims this

amounts to a failure to supervise subordinates and to provide a safe environment. Plaintiff seeks $2.2 million dollars. (Doc. 12 at 7). Based on the allegations in the Complaint, the Court will designate the following claim: Claim 1: Eighth Amendment failure to protect claim against Defendants Crooks and Brown;

Claim 2: Eighth Amendment deliberate indifference claim against Defendants Crooks and Brown for failing to offer medical care. The parties and the Court will use these designations in all future pleadings and orders unless otherwise directed by a judicial officer of this Court. Any claim that is mentioned

in the Complaint but not addressed in this Order is considered dismissed without prejudice as inadequately pled under Twombly. See Bell Atl. 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”). PRELIMINARY DISMISSAL Plaintiff mentions a Monell1 violation in his amended complaint, and alleges a

supervisor created a policy or custom of allowing illegal acts or failed to adequately train subordinates. These allegations are threadbare and do not plausibly identify a discrete policy or custom, let alone the individual(s) responsible for the policy or custom. It is also noteworthy that Monell liability is typically applied to entities like medical contractors in the state prison system, or to jail or county officials in the county jail

context. It is rare to apply Monell liability to a state employee, and is only contemplated in terms of the injunctive relief context because a state inmate cannot secure monetary compensation against a state official in official capacity. See e.g., Dixon v. Brown, 2021 WL 1171657 at *5 (S.D. Ill. Mar. 29, 2021) (explaining that a state official may be held liable in official capacity under § 1983 solely for injunctive relief). Here, Plaintiff seeks only

monetary compensation, so he could not proceed against a state employee in official

1 Monell v. Dept. of Social Serv. Of City of New York, 436 U.S. 658 (1978). capacity for the relief he seeks under Monell. For all of these reasons, these allegations are dismissed as insufficiently pled.

ANALYSIS To establish a failure to protect claim under the Eighth Amendment, a plaintiff must allege “(1) that he was incarcerated under conditions posing a substantial risk of serious harm and (2) that the defendants acted with deliberate indifference to his health or safety.” Santiago v. Walls, 599 F.3d 749, 756 (7th Cir. 2010). Under the Eighth

Amendment, correctional officials have a constitutional duty to protect inmates from violence. Farmer v. Brennan, 511 U.S. 825, 844 (1994). But “prisons are dangerous places. Inmates get there by violent acts, and many prisoners have a propensity to commit more.” Grieveson v. Anderson, 538 F.3d 763, 777 (7th Cir. 2008). A failure to protect claim cannot be predicated “merely on knowledge of general risks of violence in a detention facility.”

Brown v. Budz, 398 F.3d 904, 913 (7th Cir. 2005); see also, Moore v. Western Illinois Corr. Ctr., 89 F.4th 582 (7th Cir. 2023) (finding that a guard’s knowledge of prior horseplay and annoyances by one inmate to another was not sufficient to demonstrate a failure to protect from a serious violent attack). Instead, the plaintiff must establish that “the defendant had actual knowledge of

an impending harm easily preventable, so that a conscious, culpable refusal to prevent the harm can be inferred from the defendant's failure to prevent it.” Santiago, 599 F.3d at 756. “[N]egligence, or even gross negligence does not equate to deliberate indifference” and does not state a claim for a violation of the Eighth Amendment. Johnson v. Dominguez, 5 F.4th 818, 825 (7th Cir. 2021). Related to the failure to protect, inmates may also allege that prison staff failed to intervene in an ongoing assault. See Eddmonds v. Walker, 317

Fed. App’x 556, 558-59 (7th Cir. 2009). To establish such a claim, an inmate must allege the onlooker had a reasonable opportunity to intervene. Plaintiff has not added any meaningful new facts to his amended complaint.

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Related

Santiago v. Walls
599 F.3d 749 (Seventh Circuit, 2010)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
McCree v. Grissom
657 F.3d 623 (Seventh Circuit, 2011)
David Brown v. Timothy Budz
398 F.3d 904 (Seventh Circuit, 2005)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Ammons v. Gerlinger
547 F.3d 724 (Seventh Circuit, 2008)
Rodriguez v. Plymouth Ambulance Service
577 F.3d 816 (Seventh Circuit, 2009)
Grieveson v. Anderson
538 F.3d 763 (Seventh Circuit, 2008)
Levi A. Lord v. Joseph Beahm
952 F.3d 902 (Seventh Circuit, 2020)
Always Towing & Recovery Inc. v. City of Milwaukee
2 F.4th 695 (Seventh Circuit, 2021)
Zachary Johnson v. Bessie Dominguez
5 F.4th 818 (Seventh Circuit, 2021)
Mitchell Zimmerman v. Glenn Bornick
25 F.4th 491 (Seventh Circuit, 2022)

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Payne v. Crooks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/payne-v-crooks-ilsd-2025.