Phillip Anglin v. Lisa Draper et al.

District Court, C.D. Illinois·Decided April 17, 2026·No. 1:24-cv-01424·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION

PHILLIP ANGLIN, Plaintiff,

v. Case No. 1:24-cv-01424-JEH

LISA DRAPER et al., Defendants.

Order Before the Court is a Motion for Summary Judgment (Doc. 70) filed by Defendant Daniel J. Baker, a corrections officer at the Livingston County Jail (“Jail”). Plaintiff Phillip Anglin, an inmate at Western Illinois Correctional Center, filed his response (Doc. 83), Baker has replied (Doc. 88), and Plaintiff has filed a surreply (Doc. 90). Baker’s dispositive motion is granted for the following reasons. I In February 2025, Plaintiff filed an Amended Complaint (Doc. 10), alleging constitutional violations committed at the Jail. Following screening, the Court determined that Plaintiff’s account stated the following Fourteenth Amendment claims: excessive force against Corrections Officer Baker and objectively unreasonable medical care against Jail Superintendent Lisa Draper and Dr. Zia Samad. (Mer. Rev., Doc. 9 at 7:2.) As to Defendant Baker, Plaintiff alleged that while being processed for transport on January 28, 2023, Baker, who was visibly upset, restrained him in a violent manner that caused him pain and breathlessness due to tight cuffs. (Amend. Compl., Doc. 10 at 24:108-10.) II Summary judgment should be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). “A dispute is ‘genuine’ ‘if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.’” Zaya v. Sood, 836 F.3d 800, 804 (7th Cir. 2016) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). The moving party has the burden of providing proper documentary evidence to show the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323-24 (1986). “If the moving party has properly supported his motion, the burden shifts to the non-moving party to come forward with specific facts showing that there is a genuine issue for trial.” Spierer v. Rossman, 798 F.3d 502, 507 (7th Cir. 2015). “When opposing a properly supported motion for summary judgment, the non-moving party must ‘cit[e] to particular parts of materials in the record’ or ‘show[] that the materials cited do not establish the absence … of a genuine dispute.’” Melton v. Tippeconoe County, 838 F.3d 814, 818 (7th Cir. 2016) (quoting Fed. R. Civ. P. 56(c)). All facts must be construed in the light most favorable to the nonmoving party, and all reasonable inferences must be drawn in his favor. Ogden v. Atterholt, 606 F.3d 355, 358 (7th Cir. 2010). “Only disputes over facts that might affect the outcome of the suit under the governing law will properly preclude the entry of summary judgment.” Anderson, 477 U.S. at 248. A scintilla of evidence supporting the nonmovant’s position is insufficient to defeat a motion for summary judgment; “there must be evidence on which the jury could reasonably find for the [non-movant].” Id. at 252. III A Defendant Baker’s dispositive motion includes a section listing the undisputed material facts in this case (Doc. 71 at 2-5:1-26.); see also Local Rule 7.1(D)(1)(b) (stating a motion for summary judgment must include a section listing the undisputed material facts). Under Local Rule 7.1(D)(2)(b), a party opposing a motion for summary judgment must respond to the moving party’s undisputed material facts and provide additional material facts, which must be supported by admissible evidence. Although Plaintiff filed a response (Doc. 83), it does not address Defendant Baker’s material facts. Local Rule 7.1(D)(2)(b) requires the nonmovant to respond to the movant’s facts, noting which are undisputed material facts, disputed material facts, disputed immaterial facts, or undisputed immaterial facts. Civil LR 7.1(D)(2)(b)(1-4). Even after Baker noted Plaintiff’s omission in his reply (Doc. 88 at 1-2), Plaintiff does not explicitly address the deficiency in his surreply (Doc. 90). Thus, Plaintiff does not comply with the Court’s instructions that “[e]ach claim of disputed fact must be supported by evidentiary documentation referenced by specific page.” Civil LR 7.1(D)(2)(b)(2). Although Plaintiff’s failure to comply with the Court’s Local Rules is “deemed an admission of the fact” under Local Rule LR 7.1(D)(2)(b)(6), summary judgment in Defendants’ favor is not automatic. See Raymond v. Ameritech Corp., 442 F.3d 600, 608 (7th Cir. 2006) (“[A] nonmovant’s failure to respond to a summary judgment motion, … does not, of course, automatically result in judgment for the movant.”) The ultimate burden remains with Defendants to demonstrate they are entitled to judgment as a matter of law. Id. Therefore, the following material facts are based on the parties’ properly supported briefs and the Court’s review of the record provided. B At about 12:50 a.m., Defendant Baker was notified that Plaintiff required transportation to the hospital. (Baker Decl., Doc. 71-2 at 1:2.) Defendant Baker was released from his duties in master control and proceeded to escort Plaintiff from his room to the booking area. (Id. at 1:3.) After arriving at the booking area, Baker began preparing Plaintiff for transport to the hospital by placing him in a waist chain and handcuffs per jail policy. (Id. at 1-2:5-7.) Plaintiff acknowledged that every detainee is required to submit to restraints before being transported. (Pl. Dep., Doc. 71-1 at 44:14-22.) Defendant Baker noted that while applying the restraints, Plaintiff did not exhibit signs of injury, distress, or impaired circulation, and Baker had no indication that Plaintiff’s hand restraints were too tight until Plaintiff communicated his concerns. (Baker Decl., Doc. 71-2 at 2:8.) Immediately after Plaintiff did so, Baker loosened Plaintiff’s handcuffs. (Id. at 2:9.) Plaintiff testified that the handcuffs were too tight for more than thirty seconds but “probably not more than a minute,” and that after he protested, the cuffs were loosened. (Pl. Dep., Doc. 71-1 at 50:11-17.) Plaintiff was thereafter transported to the hospital, where no physical injuries related to Plaintiff’s allegations against Defendant Baker were documented. (Pl. Med. Rec., Doc. 71-3.) Plaintiff admitted that he received no medical treatment for his wrists at the hospital, which he visited for a leg injury unrelated to this incident. (Pl. Dep., Doc. 71-1 at 50:23-51:1.) In the relevant grievance Plaintiff submitted regarding his encounter with Baker on January 28, 2023, Plaintiff did not allege wrist injuries. (Amend. Compl., Doc. 10-1 at 11-20.) C As a pretrial detainee, Plaintiff’s excessive force claim arises under the Due Process Clause of the Fourteenth Amendment rather than the Eighth Amendment’s proscription against cruel and unusual punishment. Estate of Cole v. Fromm, 94 F.3d 254, 259 n.1 (7th Cir. 1996). In analyzing an excessive force claim under the Fourteenth Amendment, “a court must determine whether the force was objectivel

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Phillip Anglin v. Lisa Draper et al., (C.D. Ill. 2026).

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