Richardson v. Miles

CourtDistrict Court, N.D. Illinois
DecidedMarch 21, 2025
Docket1:23-cv-00784
StatusUnknown

This text of Richardson v. Miles (Richardson v. Miles) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richardson v. Miles, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JAMIE RICHARDSON (2020-1128138), ) ) Plaintiff, ) No. 23-cv-784 ) v. ) Judge Jeffrey I. Cummings ) MILES, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiff, Jamie Richardson, brings this action pursuant to 42 U.S.C. §1983, alleging that his Fourteenth Amendment rights were violated when defendant Cook County Sheriff’s Officers Bernal, Downes, Harper, Hejaz, Jefferson, Miles, Santana, and Valadez used excessive force while plaintiff was restrained during an incident at the Cook County Jail on December 4, 2022. Defendants have collectively moved for summary judgment, (Dckt. #74), arguing that: (1) they are entitled to qualified immunity; (2) there is no evidence of excessive force; and (3) plaintiff’s claims are barred by the holding in Heck v. Humphrey, 512 U.S. 477, 487 (1994), and its progeny. Because there remains a disputed issue of material fact as to whether defendants used excessive force during the incident on December 4, 2022, and success on a claim brought pursuant to 42 U.S.C. §1983 is not incompatible with plaintiff’s disciplinary record in this case, defendants’ motion for summary judgment is denied. I. LEGAL STANDARD A. Standard for Summary Judgment Summary judgment is appropriate when the moving party shows “that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). “A genuine dispute is present if a reasonable jury could return a verdict for the nonmoving party, and a fact is material if it might bear on the outcome of the case.” Wayland v. OSF Healthcare Sys., 94 F.4th 654, 657 (7th Cir. 2024); FKFJ, Inc. v. Village of Worth, 11 F.4th 574, 584 (7th Cir. 2021) (the existence

of a factual dispute between the parties will not preclude summary judgment unless it is a genuine dispute as to a material fact). When the moving party has met that burden, the non-moving party cannot rely on mere conclusions and allegations to concoct factual issues. Balderston v. Fairbanks Morse Engine Div. of Coltec Indus., 328 F.3d 309, 320 (7th Cir. 2003). Instead, it must “marshal and present the court with the evidence [it] contends will prove [its] case.” Goodman v. Nat. Sec. Agency, Inc., 621 F.3d 651, 654 (7th Cir. 2010); Lewis v. CITGO Petroleum Corp., 561 F.3d 698, 704 (7th Cir. 2009). Thus, a mere “scintilla of evidence” supporting the non-movant’s position does not suffice; there must be evidence on which the jury could reasonably find for the non-moving party. Anderson, 477 U.S. at 248. Of course, “[i]t is not the duty of the court to scour the record

in search of evidence to defeat a motion for summary judgment; rather, the nonmoving party bears the responsibility of identifying the evidence upon which he relies.” Harney v. Speedway SuperAmerica, LLC, 526 F.3d 1099, 1104 (7th Cir. 2008). In determining whether a genuine issue of material fact exists, all facts and reasonable inferences must be drawn in the light most favorable to the non-moving party. King v. Hendricks Cnty. Commissioners, 954 F.3d 981, 984 (7th Cir. 2020). Yet, the nonmovant “is not entitled to the benefit of inferences that are supported only by speculation or conjecture.” Boss v. Castro, 816 F.3d 910, 916 (7th Cir. 2016). Ultimately, summary judgment is granted only if “no reasonable trier of fact could find in favor of the non-moving party.” Hoppe v. Lewis Univ., 692 F.3d 833, 838 (7th Cir. 2012) (cleaned up). 1. Requirements of Local Rule 56.1 Local Rule 56.1 governs the procedures for filing and responding to motions for

summary judgment in this court. The rule is intended “to aid the district court, ‘which does not have the advantage of the parties’ familiarity with the record and often cannot afford to spend the time combing the record to locate the relevant information,’ in determining whether a trial is necessary.” Delapaz v. Richardson, 634 F.3d 895, 899 (7th Cir. 2011) (cleaned up). Local Rule 56.1(a) requires the moving party to provide a statement of material facts that complies with Local Rule 56.1(d). LR 56.1(a)(2). In turn, Local Rule 56.1(d) requires that “[e]ach asserted fact must be supported by citation to the specific evidentiary material, including the specific page number, that supports it. The court may disregard any asserted fact that is not supported with such a citation.” LR 56.1(d)(2). The opposing party must then respond to the movant’s proposed statements of fact.

Schrott v. Bristol-Myers Squibb Co., 403 F.3d 940, 944 (7th Cir. 2005); LR 56.1(e). In the case of any disagreement, “a party must cite specific evidentiary material that controverts the fact and must concisely explain how the cited material controverts the asserted fact. Asserted facts may be deemed admitted if not controverted with specific citations to evidentiary material.” LR 56.1(e)(3). “[M]ere disagreement with the movant’s asserted facts is inadequate if made without reference to specific supporting material.” Smith v. Lamz, 321 F.3d 680, 683 (7th Cir. 2003). Here, because plaintiff is proceeding pro se, defendants served him with a “Notice to Pro Se Litigant Opposing Motion for Summary Judgment” as required by Local Rule 56.2. (Dckt. #66). Plaintiff then responded to the motion for summary judgment but did not fully and properly respond to defendants’ L.R. 56.1 statement of facts because he failed to support at least some of his responses with citations to the record. (See, e.g., Dckt. #78 at 6 (failing to respond to DSOF ¶¶31-32 with citations to the record)). Additionally, some of plaintiff’s responses are argumentative, or quibble with the record in a manner as to render the dispute not material. (Id.

(disputing the name of the nurse who provided him with medical care after the incident in response to DSOF ¶¶27-28)). As such, the Court will consider plaintiff’s responses only to the extent they are supported by the record or contain information about which plaintiff could properly testify. See James v. Hale, 959 F.3d 307, 315 (7th Cir. 2020); Sistrunk v. Khan, 931 F.Supp.2d 849, 854 (N.D.Ill. 2013). Additionally, the Court need not consider factual assertions that conflict with prior, sworn testimony, as well as hearsay statements, legal arguments and conclusions set forth as “facts,” any declaration that speculates as to other people’s mindsets, and statements concerning matters about which only an expert could properly testify. See Jones v. DeJoy, No. 18 CV 1213, 2020 WL 6716218, at *1 (N.D.Ill. Nov. 16, 2020) (striking offending portions of

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Richardson v. Miles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richardson-v-miles-ilnd-2025.