Reames v. Roxana Police Department

CourtDistrict Court, S.D. Illinois
DecidedOctober 17, 2022
Docket3:22-cv-01832
StatusUnknown

This text of Reames v. Roxana Police Department (Reames v. Roxana Police Department) 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
Reames v. Roxana Police Department, (S.D. Ill. 2022).

Opinion

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

BRANDON A. REAMES, #63291, ) ) Plaintiff, ) ) vs. ) Case No. 22-cv-01832-JPG ) ROXANA POLICE DEPARTMENT, ) JOHN DOE 1, ) JOHN DOE 2, ) and JOHN DOE 3, ) ) Defendants. )

MEMORANDUM & ORDER GILBERT, District Judge: Plaintiff Brandon Reames, an inmate at Madison County Jail, brings this civil rights action pursuant to 42 U.S.C. § 1983 against Officer John Doe 1, Officer John Doe 2, Chief of Police John Doe 3, and Roxana Police Department for an unlawful pat down that occurred in August 2021 in Hartford, Illinois. (Doc. 1). He seeks money damages. (Id.). 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 a 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). The Complaint Plaintiff sets forth the following allegations in the Complaint (Doc. 1, pp. 11-12): In August 2021, Plaintiff was driving to Casey’s General Store in Hartford, Illinois, when three officers from Roxana Police Department pulled him over and conducted a pat down search. He does not identify the officers individually in the statement of his claim. However, he names Officer John Doe 1, Officer John Doe 2, Chief of Police John Doe 3, and Roxana Police Department as parties in the case caption and list of defendants. (Id.). Plaintiff alleges that, after he was pulled over, he identified himself and asked the officers

to explain why he was stopped. (Id. at 11). One officer said “because this is your vehicle.” (Id.). Plaintiff explained that the vehicle belonged to his father and again asked why he was pulled over. Another officer said, “Search him.” (Id.). In response, one of them stuck both of his hands down Plaintiff’s pants, reached inside his boxers, and touched his “buttocks crack.” (Id.). The officer then touched Plaintiff’s penis with his bare hands, prompting Plaintiff to push the officer off of him. (Id.). Roxana’s Chief of Police asked Plaintiff what he thought about “his officers (sic) shakedown,” and Plaintiff reported being sexually assaulted. (Id.). He informed the officers and his public defender of the same thing. (Id. at 12). They promised to open an investigation but never did. (Id.). Plaintiff was instructed to file this lawsuit instead. (Id.).

Discussion Based on the allegations, the Court finds it convenient to organize the pro se Complaint into the following enumerated Counts: Count 1: Fourth Amendment claim against Defendants for the unlawful stop of Plaintiff on Illinois Route 3 near Hartford, Illinois, in August 2021.

Count 2: Fourth Amendment claim against Defendant for the unlawful pat down of Plaintiff near Hartford, Illinois, in August 2021.

Count 3: Monell claim against Roxana Police Department and all other defendants for the unlawful stop and search of Plaintiff in August 2021.

Count 4: Fourteenth Amendment claim against Defendants for conducting a search of Plaintiff that violated his right to equal protection of the law. Count 5: Eighth Amendment claim against Defendants for conducting a search of Plaintiff that violated his right to be free from cruel and unusual punishment.

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). Counts 1 and 2 The Fourth Amendment guards against unreasonable searches and seizures. U.S. CONST. Amend. IV. The reasonableness of a search or seizure “within the meaning of the Fourth Amendment depends upon the facts and circumstances of each case.” South Dakota v. Opperman, 428 U.S. 364, 375 (1976). For example, officers may conduct brief investigatory stops of a suspect and temporarily detain him for questioning or a limited investigation, “if they have reasonable suspicion based on articulable facts that a crime is about to be or has been committed.” United States v. Carlisle, 614 F.3d 750 (7th Cir. 2010) (citations omitted); United States v. LePage, 477 F.3d 485, 487 (7th Cir. 2007). The requisite level of suspicion is less than probable cause. United States v. Sokolow, 490 U.S. 1, 7 (1989). Officers may also conduct a warrantless “protective search” to look for weapons that might be used to harm the officer. Minnesota v. Dickerson, 508 U.S. 366, 373 (1993). An officer may even detain an item, if the officer has reasonable suspicion to believe that it contains a weapon, contraband, or other evidence of a crime and the “exigencies of the circumstances demand it or some other recognized exception to the warrant requirement is present.” United States v. Place, 462 U.S. 696, 708-09 (1983). A warrantless search or seizure may also be conducted to preserve evidence when it is in immediate risk of removal or destruction.

Ker v. State of California, 374 U.S. 23, 40-42 (1963) (warrantless seizure of marijuana supported by reasonable belief drug could be easily destroyed or hidden). In contrast, an arrest requires a warrant or probable cause. United States v. Vega, 72 F.3d 507, 515 (7th Cir. 1995). The probable cause determination hinges on “the common-sense judgment of the officers based on the totality of the circumstances.” Jackson v. Parker, 627 F.3d 634, 638 (7th Cir. 2010). If probable cause is found to exist, it serves as an “absolute defense to any claim under Section 1983 against police officers for wrongful arrest.” Jackson, 627 F.3d at 638 (quoting Mustafa v. City of Chicago, 442 F.3d 544, 547 (7th Cir. 2006)). The Complaint falls short of stating a claim against the defendants for an unlawful stop

(Count 1) or search (Count 2) because the allegations do not specify which defendants were responsible for what misconduct. Section 1983 liability hinges on personal responsibility for a constitutional deprivation. Sanville v. McCaughtry, 266 F.3d 724, 740 (7th Cir. 2001). The doctrine of respondeat superior does not apply to Section 1983 actions. Id. Therefore, Plaintiff must set forth sufficient allegations against each named defendant to establish his or her personal involvement in a violation of his constitutional rights. Plaintiff names Officer John Doe 1, Officer John Doe 2, Chief of Police John Doe 3, and Roxana Police Department as defendants in the Complaint. (Doc. 1, pp. 1-3). In the statement of his claim, he does not sufficiently distinguish between them. The Court cannot tell who stopped

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Ker v. California
374 U.S. 23 (Supreme Court, 1963)
South Dakota v. Opperman
428 U.S. 364 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
United States v. Place
462 U.S. 696 (Supreme Court, 1983)
United States v. Sokolow
490 U.S. 1 (Supreme Court, 1989)
Minnesota v. Dickerson
508 U.S. 366 (Supreme Court, 1993)
Thomas v. Cook County Sheriff's Department
604 F.3d 293 (Seventh Circuit, 2010)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jackson v. Parker
627 F.3d 634 (Seventh Circuit, 2010)
Jerome R. MacLin v. Deputy Sheriff Paulson
627 F.2d 83 (Seventh Circuit, 1980)
Harriett L. McMillian v. Gerald N. Svetanoff, Judge
878 F.2d 186 (Seventh Circuit, 1989)
William McNabola v. Chicago Transit Authority
10 F.3d 501 (Seventh Circuit, 1993)
David Brown v. Timothy Budz
398 F.3d 904 (Seventh Circuit, 2005)
Anna Mustafa v. City of Chicago
442 F.3d 544 (Seventh Circuit, 2006)

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Reames v. Roxana Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reames-v-roxana-police-department-ilsd-2022.